T.C. Memo. 2003-177
UNITED STATES TAX COURT
FILOMENA PAHAMOTANG, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6311-02L. Filed June 17, 2003.
Filomena Pahamotang, pro se.
Hieu C. Nguyen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: The controversy in this case involves the
question of whether respondent is entitled to go forward with the
collection of petitioner’s outstanding and unpaid 1994 tax
liability. Respondent moved for summary judgment, and the motion
was set for hearing at the Court’s March 24, 2003, Los Angeles,
California, trial session. At the hearing, petitioner advised
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