T.C. Memo. 2004-264
UNITED STATES TAX COURT
ROBERT LEE, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15735-03L. Filed November 18, 2004.
Robert Lee, Jr., pro se.
Cindy Wofford, Alan Levine, and Erin K. Huss, for
respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This collection review
case is before the Court on respondent’s Motion for Summary
Judgment.1 As discussed in detail below, we conclude that there
1 Section references are to sections of the Internal
Revenue Code, as amended, and Rule references are to the Tax
Court Rules of Practice and Procedure.
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