T.C. Memo. 2002-296 UNITED STATES TAX COURT STEVEN JOHN RENNIE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2539-02L. Filed December 2, 2002. Steven John Rennie, pro se. John W. Strate, for respondent. MEMORANDUM OPINION GERBER, Judge: Respondent, in a motion filed on August 26, 2002, moved for summary judgment on the questions of whether respondent may proceed with collection and whether a section 66731 penalty should be imposed against petitioner. With respect 1 All section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.Page: 1 2 3 4 5 6 7 8 9 10 Next
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