T.C. Memo. 2003-4
UNITED STATES TAX COURT
MORRIS TABAK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11465-01L. Filed January 7, 2003.
R. Scott Shieldes and Karen Baker, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent’s Motion For Summary Judgment, filed pursuant to
Rule 121.1 Respondent contends that there is no dispute as to
any material fact with respect to this lien action and that
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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