Arthur Manjourides - Page 1

                                 T.C. Memo. 2005-242                                  

                               UNITED STATES TAX COURT                                

                          ARTHUR MANJOURIDES, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 19979-04L.           Filed October 13, 2005.                

               Timothy J. Burke, for petitioner.                                      
               Nina P. Ching, for respondent.                                         

                                 MEMORANDUM OPINION                                   

               THORNTON, Judge:  This matter is before the Court on                   
          respondent’s motion for summary judgment pursuant to Rule 121.1             
          The issue for decision is whether respondent may proceed to                 
          collect by levy unpaid Federal income taxes with respect to                 
          petitioner’s 1996 tax year.  After considering respondent’s                 
          motion and petitioner’s response thereto, we conclude that a                

               1 Unless otherwise indicated, all Rule references are to the           
          Tax Court Rules of Practice and Procedure, and all section                  
          references are to the Internal Revenue Code, as amended.                    

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