MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
The controversy in this case involves the question of whether respondent is entitled to go forward with the collection of petitioner's outstanding and unpaid 1994 tax liability. Respondent moved for summary judgment, and the motion was set for hearing at the Court's March 24, 2003, Los Angeles, California, trial session. At the hearing, petitioner advised the Court that she had no evidence to present...
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