David and Ludmila Klet - Page 10

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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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