T.C. Memo. 2002-267
UNITED STATES TAX COURT
CHARLES G. AND DAPHNE C. M. HALL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2906-02L. Filed October 21, 2002.
Charles G. and Daphne C. M. Hall, pro sese.
Alan J. Tomsic and Karen Lynne Baker, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent’s motion for summary judgment, filed
pursuant to Rule 121.1 Respondent contends that there is no
dispute as to any material fact with respect to this lien action,
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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