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DIFFEE, JR. v. COMMISSIONER

Dkt. No. 16567-06.

94 T.C.M. 371 (2007)

T.C. Memo. 2007-304

Alfred A. Diffee, Jr. and Norma J. Diffee v. Commissioner.

United States Tax Court.

October 9, 2007.

Attorney(s) appearing for the Case

Paul R. Tom, for petitioners.

G. Chad Barton, for respondent.

MEMORANDUM OPINION

MARVEL, Judge:

This matter is before the Court on respondent's motion for summary judgment, filed under Rule 121.1

Background

This is an appeal from respondent's determination upholding the proposed use of a levy to collect petitioners' unpaid Federal income tax liabilities for 2001 and 2002. Petitioners resided in Oakhurst, Oklahoma, when the petition was filed.

On July 2,...

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