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2. Held, further, summary judgment is appropriate
since P has averred no facts sufficient to show error
in the taxes assessed on the basis of his 1994 and 1996
returns or otherwise with respect to the notice of
determination.
Elizabeth A. Maresca and Katherine Scovin (specially
recognized), for petitioner.
Peggy Gartenbaum, for respondent.
OPINION
HALPERN, Judge: This case is before the Court to review a
determination made by one of respondent’s Appeals officers (the
determination) that respondent may proceed to collect by levy
unpaid income taxes assessed by respondent against petitioner for
1994 and 1996 (the assessments). We review such determinations
pursuant to section 6330(d)(1).1 Petitioner has assigned error to
the determination, and, as we understand that assignment, it is
principally that, in making the determination, the Appeals
officer failed to consider the accuracy of the assessments, which
petitioner claims do not reflect his true income tax liabilities
for the years in question. Respondent denies that the Appeals
officer erred, and he moves for a summary disposition in his
favor (the motion), that the determination be sustained, on the
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011