T.C. Memo. 2004-3
UNITED STATES TAX COURT
PERRY GOLDMAN AND SANDRA GOLDMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14639-02L. Filed January 5, 2004.
Perry Goldman and Sandra Goldman, pro sese.
Leonard T. Provenzale, for respondent.
MEMORANDUM OPINION
GERBER, Judge: Respondent, in a motion filed on October 27,
2003, moved for summary judgment on the question of whether he
may proceed with the collection process with respect to
petitioners. Respondent alleges that the section 6330
prerequisites have been met and that he should be allowed to
proceed with collection of petitioners’ assessed and outstanding
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