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ROBERTSON v. COMMISSIONER

Docket No. 10113-02L.

87 T.C.M. 1112 (2004)

T.C. Memo. 2004-72

Early Robertson, Jr. v. Commissioner.

United States Tax Court.

Filed March 18, 2004.

Attorney(s) appearing for the Case

Early Robertson, Jr., pro se.

Marshall R. Jones 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. The instant proceeding arises from a petition for judicial review filed in response to a Notice of Determination Concerning Collection Actions(s) Under Section 6330 of the Internal Revenue Code.1 The issue for decision is whether respondent may proceed with collection action as so determined.

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