T.C. Memo. 2003-16
UNITED STATES TAX COURT
BENJAMIN B. AND CAROLYN M. HAINES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8296-02L. Filed January 21, 2003.
Benjamin B. and Carolyn M. Haines, pro sese.
Hieu C. Nguyen, for respondent.
MEMORANDUM OPINION
GERBER, Judge: Respondent, in a motion filed on November
20, 2002, moved for summary judgment on the questions of whether
he may proceed with collection and whether a section 66731
1 All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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