T.C. Memo. 2002-180
UNITED STATES TAX COURT
RAINER B. AND SONJA D. WAGNER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13046-01L. Filed July 31, 2002.
Rainer B. and Sonja D. Wagner, pro sese.
Wendy S. Harris and Scott Hovey, for respondent.
MEMORANDUM OPINION
POWELL, Special Trial Judge: This matter is before the
Court on respondent’s Motion For Summary Judgment And To Impose A
Penalty Under I.R.C. Section 6673, 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 respondent’s
determination to proceed with collection of petitioners’
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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