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REWERTS v. COMMISSIONER

Docket No. 2545-02L.

88 T.C.M. 401 (2004)

T.C. Memo. 2004-248

Richard Rewerts v. Commissioner.

United States Tax Court.

November 1, 2004.

Attorney(s) appearing for the Case

Richard Rewerts, pro se.

Rebecca S. Duewer-Grenville, for respondent.

MEMORANDUM OPINION

HAINES, Judge:

This matter is before us on respondent's motion for summary judgment pursuant to Rule 121.1 The issue for decision is whether there was an abuse of discretion in respondent's determination that collection action could proceed for Federal income tax liabilities for 1998.

Background

At the time his petition was filed, petitioner resided in Nice, California.

On March...

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