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MANJOURIDES v. COMMISSIONER

Docket No. 19979-04L.

90 T.C.M. 396 (2005)

T.C. Memo. 2005-242

Arthur Manjourides, v. Commissioner.

United States Tax Court.

October 13, 2005.

Attorney(s) appearing for the Case

Timothy J. Burke, for petitioner.

Nina P. Ching, for respondent.

MEMORANDUM OPINION

THORNTON, Judge:

This matter is before the Court on respondent's motion for summary judgment pursuant to Rule 121.1 The issue for decision is whether respondent may proceed to collect by levy unpaid Federal income taxes with respect to petitioner's 1996 tax year. After considering respondent's motion and petitioner's response thereto, we conclude that a hearing on respondent's motion would not materially assist...

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