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PICCHIOTTINO v. COMMISSIONER

Docket No. 785-04L.

88 T.C.M. 351 (2004)

T.C. Memo. 2004-232

Scott Perry Picchiottino v. Commissioner.

United States Tax Court.

October 12, 2004.

Attorney(s) appearing for the Case

Scott Perry Picchiottino, pro se.

Jonae A. Harrison, for respondent.

MEMORANDUM OPINION

WHERRY, Judge:

This case is before the Court on respondent's motion for summary judgment pursuant to Rule 121.1 The instant proceeding arises from a petition for judicial review filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The issue for decision is whether respondent may proceed with collection action as so determined.

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