Ferrel Benjamin Gibbs - Page 1

                                 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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