MEMORANDUM OPINION
DEAN, Special Trial Judge.
This case is before the Court on respondent's motion for partial summary judgment filed pursuant to Rule 121. All Rule references are to the Tax Court Rules of Practice and Procedure. All section references are to the Internal Revenue Code of 1986, as amended.
The motion arises in the context of a petition filed in response to a notice of determination concerning collection action under section 6330 sent...
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