T.C. Memo. 2006-27
UNITED STATES TAX COURT
FRED DEUTSCH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3583-05L. Filed February 15, 2006.
Ira B. Stechel and John T. Morin, for petitioner.
William C. Bogardus, for respondent.
MEMORANDUM OPINION
JACOBS, Judge: This collection review case is before the
Court on respondent’s motion for partial summary judgment
pursuant to Rule 121.1 As explained in detail below, we shall
grant respondent’s motion.
1Rule references are to the Tax Court Rules of Practice and
Procedure. Section references are to the Internal Revenue Code.
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