Sue Taylor - Page 1

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                                 T.C. Memo. 2004-25                                   


                               UNITED STATES TAX COURT                                



                              SUE TAYLOR, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      



               Docket No. 13491-03L.            Filed February 3, 2004.               


               Sue Taylor, pro se.                                                    
               Erin K. Huss, for respondent.                                          


                              MEMORANDUM OPINION                                      

               GERBER, Judge:  Respondent, in a motion filed on November 6,           
          2003, moved for summary judgment on the question of whether                 
          respondent may proceed with collection of Federal income tax                
          assessed against petitioner.  Petitioner, on November 14, 2003,             
          filed a cross-motion for summary judgment on the question of