Kelly V. Kaeckell - Page 1

                                 T.C. Memo. 2002-114                                  

                               UNITED STATES TAX COURT                                

                          KELLY V. KAECKELL, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6607-01L.            Filed May 7, 2002.                     

               Kelly V. Kaeckell, pro se.                                             
               Karen L. Baker and Charles M. Berlau, for respondent.                  

                                 MEMORANDUM OPINION                                   

               ARMEN, 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 levy action, and that                

               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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