FOLEY v. COMMISSIONER

Dkt. No. 11602-06L.

94 T.C.M. 210 (2007)

T.C. Memo. 2007-242

Kevin F. Foley and Shula K. Foley v. Commissioner.

United States Tax Court.

August 23, 2007.


Attorney(s) appearing for the Case

Mark A Pridgeon, for petitioners.

Trent D. Usitalo, for respondent.


MEMORANDUM OPINION

SWIFT, Judge:

This matter is before us under Rule 121 on the parties' cross-motions for summary judgment. The underlying issue in this collection case is whether respondent's Appeals Office abused its discretion in sustaining respondent's proposed levy action against petitioners' residence.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references...

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