T.C. Memo. 2003-62
UNITED STATES TAX COURT
MICHAEL A. MILNES AND ESTHER N. MILNES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8612-02L. Filed March 4, 2003.
Michael A. Milnes and Esther N. Milnes, pro se.
Trent D. Usitalo, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: This matter is before the Court on
respondent’s motion for summary judgment. The issue is whether
it is appropriate to decide by summary judgment that respondent’s
determination to proceed with collection of petitioners’ tax
liabilities was not an abuse of discretion. For reasons stated
below, we will grant respondent’s motion.
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