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Karara v. Commissioner

Dkt. No. 7748-02L.

87 T.C.M. 1391 (2004)

T.C. Memo. 2004-133

Said M. Karara v. Commissioner.

United States Tax Court.

June 2, 2004.

Attorney(s) appearing for the Case

Said M. Karara, pro se.

D'Aun E. Clark, for respondent.

MEMORANDUM OPINION

GERBER, Chief Judge:

Respondent moved for summary judgment on the question of whether he may proceed with the collection of petitioner's 1993 and 1994 tax liabilities. Respondent contends that all section 63301 prerequisites have been met and that he should be allowed to proceed with collection. Petitioner filed a cross-motion for summary judgment, raising several arguments as to why respondent should not be...

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