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MICHAEL v. COMMISSIONER

Docket No. 21341-07L.

133 T.C. 237 (2009)

ANTHONY G. MICHAEL, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 8, 2009.

Attorney(s) appearing for the Case

David A. Salim, for petitioner.

A. Gary Begun, for respondent.

OPINION

GOEKE, 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 abused his discretion in sustaining a levy to collect tax preparer penalties under section 6694 for 1989, 1990, and 1991. Petitioner opposes respondent's motion for summary judgment and argues that the Court should...

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