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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 a
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