MEMORANDUM OPINION
DEAN, Special Trial Judge:
This case is before the Court on respondent's motion for summary judgment filed pursuant to Rule 121. Rule references are to the Tax Court Rules of Practice and Procedure. 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(s) Under Section 6320 and/or 6330 that respondent...
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