T.C. Memo. 2003-210
UNITED STATES TAX COURT
ROBERT H. DEPUTY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8183-02L. Filed July 16, 2003.
Robert H. Deputy, pro se.
Minakshi Tyagi-Jayasinghe, for respondent.
MEMORANDUM OPINION
GERBER, Judge: Respondent, on March 10, 2003, moved for
summary judgment on two questions: (1) Whether respondent may
proceed with collection of various income taxes and penalties
assessed against petitioner and (2) whether petitioner is liable
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