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BETHEA v. COMMISSIONER

Docket No. 7957-02L.

86 T.C.M. 403 (2003)

T.C. Memo. 2003-278

Michael W. Bethea v. Commissioner.

United States Tax Court.

Filed September 24, 2003.

Attorney(s) appearing for the Case

Michael W. Bethea, pro se.

Linda J. Wise and Robert W. West, for the respondent.

MEMORANDUM OPINION

WHERRY, Judge:

This case is before the Court on respondent's motion for summary judgment pursuant to Rule 121 and to impose a penalty under section 6673. The instant proceeding arises from a petition for judicial review filed in response to a Notice of Determination Concerning Collection Actions(s) Under Section 6320 and/or 6330.1 The issues for decision are: (1) Whether respondent may proceed with collection...

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