T.C. Memo. 2002-190
UNITED STATES TAX COURT
JOHN W. SCHROEDER, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8820-01L. Filed August 5, 2002.
John W. Schroeder, Jr., pro se.
Rollin G. Thorley and Karen Baker, 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 All Rule references are to the Tax Court Rules of
Practice and Procedure, and, unless otherwise indicated, all
section references are to the Internal Revenue Code, as amended.
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