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MEMORANDUM OPINION
WHERRY, Judge: Petitioner invoked the Court's jurisdiction
under section 6330 in response to a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
regarding his unpaid Federal income taxes for 1983 and 1993 to
1995.1 Respondent's Office of Appeals (Appeals Office) had
determined that it was appropriate to collect petitioner's unpaid
taxes pursuant to a proposed levy. After the case was docketed,
respondent on September 20, 2004, filed a motion for summary
judgment, and petitioner filed a declaration in opposition to
respondent's motion on October 18, 2004. The Court held a
hearing on the motion for summary judgment on October 18, 2004,
and took the matter under advisement. Thereafter, on March 10,
2005, respondent filed a motion to permit levy pursuant to
section 6330(e)(2).
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). Summary judgment may be
granted with respect to all or any part of the legal issues in
controversy "if the pleadings, answers to interrogatories,
depositions, admissions, and any other acceptable materials,
1 Unless otherwise indicated, section references are to the
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure.
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