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ALANIZ v. COMMISSIONER

Docket No. 5814-03L.

89 T.C.M. 660 (2005)

T.C. Memo. 2005-4

Sal Alaniz and Ruth Alaniz v. Commissioner.

United States Tax Court.

January 11, 2005.

Attorney(s) appearing for the Case

David P. Leeper, for petitioners.

Erin K. Huss, for respondent.

MEMORANDUM OPINION

NIMS, Judge:

This case is before the Court on both parties' motions for summary judgment pursuant to Rule 121. 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. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the...

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