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KOENIG v. COMMISSIONER

Docket No. 10236-02L.

85 T.C.M. 850 (2003)

T.C. Memo. 2003-40

William G. Koenig v. Commissioner.

United States Tax Court.

Filed February 24, 2003.

Attorney(s) appearing for the Case

William G. Koenig, pro se.

Wendy S. Harris and Glenn Thomas, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge.

This matter is before the Court on respondent's Motion For Summary Judgment And To Impose A Penalty Under I.R.C. Section 6673, filed pursuant to Rule 121.1 Respondent contends that there is no dispute as to any material fact with respect to this lien action and that respondent's determination to proceed with collection of petitioner's outstanding tax liability for 1998 should be...

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