Clifford W. Miller - Page 13




                                               - 13 -                                                  
                                                      An order treating respondent’s                   
                                                motion for judgment on the                             
                                                pleadings, as supplemented, as                         
                                                respondent’s motion for summary                        
                                                judgment and granting it, and                          
                                                decision that respondent may                           
                                                proceed with the collection action                     
                                                as determined in the notice of                         
                                                determination concerning the                           
                                                collection action for the taxable                      
                                                year 1990 upon which this case is                      
                                                based, will be entered.                                



























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