T.C. Memo. 2003-47
UNITED STATES TAX COURT
GLORIA M. STARK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9570-02L. Filed February 25, 2003.
Gloria M. Stark, pro se.
Charles J. Graves, for respondent.
MEMORANDUM OPINION
THORNTON, Judge: Respondent has moved for summary judgment
on the question of whether respondent may proceed with collection
of petitioner’s outstanding tax liabilities for tax years 1994
through 1997.
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. Fla. Peach Corp. v.
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