Morris Tabak - Page 1

                                 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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