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LEMANN III v. COMMISSIONER

Dkt. No. 12857-02L.

91 T.C.M. 846 (2006)

T.C. Memo. 2006-37

Arthur A. Lemann III and Roberta A. Lemann v. Commissioner.

United States Tax Court.

March 7, 2006.

Attorney(s) appearing for the Case

Arthur A. Lemann III and Roberta A. Lemann, pro sese.

Susan S. Canavello, for respondent.

MEMORANDUM OPINION

GALE, Judge:

The petition in this case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330.1 Respondent has moved for summary judgment pursuant to Rule 121. Respondent's motion is supported by the Declaration of Daniel J. Mazaroli, the Appeals officer who conducted petitioners' section 6330 hearing...

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