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ESTATE OF SBLENDORIO v. COMMISSIONER

Dkt. No. 12325-05L.

93 T.C.M. 1130 (2007)

T.C. Memo. 2007-94

Estate of Nancy Sblendorio, Deceased, Michael F. Poppo, Executor v. Commissioner.

United States Tax Court.

April 23, 2007.

Attorney(s) appearing for the Case

Eugene B. Fischer, for petitioner.

Michelle L. Maniscalco, for respondent.

MEMORANDUM OPINION

GOEKE, Judge:

This case is before the Court for review of a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination).1 Respondent moves for summary judgment, pursuant to section 6330(c)(2)(B) and section 301.6320-1(e)(3), Q&A-E2, Proced. & Admin. Regs., because Michael Poppo, as executor of the Estate of Nancy Sblendorio, was offered and participated...

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