- 3 - most favorable to the party opposing summary judgment. Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v. Commissioner, 79 T.C. 340, 344 (1982). As explained in detail below, there is no genuine issue as to any material fact, and a decision may be rendered as a matter of law. Accordingly, we shall grant respondent’s motion for summary judgment. Background Petitioner and his wife, Sheila Mudd, filed joint Forms 1040, U.S. Individual Income Tax Return, for the taxable years 1992 to 1997 and 1999. For each of these years, the Mudds reported taxable income, partially offset by credits for withholding taxes, leaving relatively modest amounts of taxes due. However, the Mudds failed to remit the amounts due with the returns. Upon the filing of the tax returns described above, respondent entered assessments against the Mudds for the taxes reported to be due. See sec. 6201(a)(1). Respondent also entered assessments against the Mudds for statutory interest for each of the years in question. On November 16, 2000, respondent mailed the Mudds a Final Notice-–Notice of Intent to Levy and Notice of Your Right to a Hearing with regard to their tax liabilities for 1992 to 1997 and 1999. On December 13, 2000, the Mudds filed with respondent aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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