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Full or partial summary judgment may be granted only if it is
demonstrated that no genuine issue exists as to any material
fact, and a decision may be entered as a matter of law. Rule
121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520
(1992), affd. 17 F.3d 965 (7th Cir. 1994).
We conclude that there is no genuine issue as to any
material fact and that a decision may be rendered as a matter of
law.
Background
Petitioner is a self-employed realtor. Petitioner filed
delinquent Federal income tax returns for 1997 and 1999.
Petitioner failed to pay the taxes due on those returns.
On August 13, 2001, respondent issued to petitioner a Final
Notice, Notice of Intent to Levy and Notice of Your Right to a
Hearing, regarding her income tax liabilities for 1997 and 1999
(notice of intent to levy). As of the date of the notice of
intent to levy, petitioner’s 1997 and 1999 income tax
liabilities, including penalties and interest, totaled $50,536.43
and $93,936.36, respectively. As of the date of the notice of
intent to levy, petitioner had not filed her income tax return
for 2000, had made insufficient estimated tax payments toward her
year 2000 tax liability, and had not made any estimated tax
payments toward her year 2001 tax liability.
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