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.Page: 1 2 3 4 5 6 7 8 9 10 11 Next
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