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considered the pleadings and other materials in the record and
concludes that there is no genuine justiciable issue of material
fact regarding the collection matters in this case.
The Court will grant respondent’s motion for summary
judgment, except with respect to 1992 and 1995, for which
petitioners satisfied their liabilities in full, and which we
assume respondent will issue a certificate of release pursuant to
section 6325.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect to foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011