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BIRD v. COMMISSIONER

Dkt. No. 9149-06L.

93 T.C.M. 709 (2007)

T.C. Memo. 2007-18

Rogan C. Bird v. Commissioner.

United States Tax Court.

January 29, 2007.

Attorney(s) appearing for the Case

Rogan C. Bird, pro se.

Alan Friday, for respondent.

MEMORANDUM OPINION

WELLS, Judge:

This matter is before the Court on respondent's motion for summary judgment pursuant to Rule 121.1 The issue we must decide is whether respondent's Appeals Office abused its discretion in determining to proceed with collection of petitioner's tax liability for taxable year 2002 by levy.

Background

At the time of filing the petition in the instant case, petitioner resided...

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