T.C. Memo. 2006-41
UNITED STATES TAX COURT
ROBERT HO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1291-05L. Filed March 14, 2006.
Robert Ho, pro se.
Elaine T. Fuller, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This collection review case is
before the Court on respondent’s Motion For Summary Judgment, as
supplemented, and petitioner’s Motion For Leave To File Second
Amended Petition.1 As explained in detail below, we shall grant
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
(continued...)
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