T.C. Memo. 2005-295
UNITED STATES TAX COURT
GLORIA POMERANTZ, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5218-05L. Filed December 22, 2005.
Richard E. Preston and Suyeun Jacqueline Pyun, for
petitioner.
Jeffrey Gold, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This collection review case is
before the Court on respondent’s Motion For Summary Judgment.1
As explained in detail below, we shall grant respondent’s motion.
1 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.
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