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YOUNG v. COMMISSIONER

Docket No. 1193-02L.

85 T.C.M. 739 (2003)

T.C. Memo. 2003-6.

Jeffrey M. Young v. Commissioner.

United States Tax Court.

Filed January 8, 2003.

Attorney(s) appearing for the Case

Jeffrey M. Young, pro se.

Jeffrey C. Venzie, for the respondent.

MEMORANDUM OPINION

RUWE, Judge:

This matter is before us on respondent's motion for summary judgment under Rule 1211 and to impose a penalty under section 6673. Respondent argues that no genuine issue exists as to any material fact and that his determination to maintain a notice of Federal tax lien filed under section 6323 should be sustained. At the time of filing the petition, petitioner resided in Scranton, Pennsylvania.<...

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