MEMORANDUM OPINION
SWIFT, Judge:
Petitioner seeks our review under section 6330(d)(1)(A) of an adverse Appeals Office collection action determination. Respondent and petitioner cross move for summary judgment on all issues.
Unless otherwise indicated, all section references are to the Internal Revenue Code for the years in issue.
Background
The following facts are established by the record.
On April 20, 2000, respondent...
Let's get started
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.
