T.C. Memo. 2004-133
UNITED STATES TAX COURT
SAID M. KARARA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7748-02L. Filed June 2, 2004.
Said M. Karara, pro se.
D’Aun E. Clark, for respondent.
MEMORANDUM OPINION
GERBER, Chief Judge: Respondent moved for summary judgment
on the question of whether he may proceed with the collection of
petitioner’s 1993 and 1994 tax liabilities. Respondent contends
that all section 63301 prerequisites have been met and that he
should be allowed to proceed with collection. Petitioner filed a
1 All section references are to the Internal Revenue Code,
and all Rule references are to the Tax Court Rules of Practice
and Procedure, unless otherwise indicated.
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