T.C. Memo. 2004-94
UNITED STATES TAX COURT
JOHNNY OWINGS MILAM, JR. AND BRENDA RAMSEY MILAM, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2538-02L. Filed April 6, 2004.
Johnny Owings Milam, Jr. and Brenda Ramsey Milam, pro sese.
Steven M. Webster, for respondent.
MEMORANDUM OPINION
GALE, Judge: This case is before us on respondent’s motion
for summary judgment under Rule 121.1 Respondent contends that
there is no dispute as to any material fact and that respondent’s
determination to proceed with the collection action at issue
1 Unless otherwise noted, 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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