Andy Hromiko - Page 1

                                 T.C. Memo. 2003-107                                  

                               UNITED STATES TAX COURT                                

                             ANDY HROMIKO, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15437-02L.              Filed April 17, 2003.               

               Andy Hromiko, pro se.                                                  
               Jeremy L. McPherson, for respondent.                                   

                                 MEMORANDUM OPINION                                   

               GALE, Judge:  This case is before us on respondent’s motion            
          for summary judgment under 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             

               1 Unless otherwise noted, all Rule references are to the Tax           
          Court Rules of Practice and Procedure, and all section references           
          are to the Internal Revenue Code as amended.                                

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