T.C. Memo. 2004-50
UNITED STATES TAX COURT
ALBERT G. COOPER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8163-02L. Filed March 5, 2004.
Joseph P. Nigro, for petitioner.
Edward J. Laubach, Jr., for respondent.
MEMORANDUM OPINION
WELLS, Chief Judge: The instant case is before us on
respondent’s motion for summary judgment pursuant to Rule 121.
Pursuant to section 6330, respondent determined that the proposed
collection action, relating to petitioner’s 1991 and 1995 taxable
years, was appropriate. Petitioner contends that respondent’s
motion for summary judgment should be denied because respondent
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