T.C. Memo. 2006-149
UNITED STATES TAX COURT
FERREL BENJAMIN GIBBS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24037-05L. Filed July 24, 2006.
Ferrel Benjamin Gibbs, pro se.
Alisha M. Harper, for respondent.
MEMORANDUM OPINION
COHEN, Judge: This case is before the Court on respondent’s
motion for summary judgment pursuant to Rule 121. The petition
in this case was filed in response to a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
(notice of determination). The issue for decision is whether
there was an abuse of discretion by the Internal Revenue Service
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