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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