T.C. Memo. 2007-323
UNITED STATES TAX COURT
JUDY HEDRICK BLOSSER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9350-06L. Filed October 29, 2007.
Brian Carl Bernhardt, for petitioner.
Veena Luthra, for respondent.
MEMORANDUM OPINION
GOEKE, Judge: This matter is before the Court on the
parties’ cross-motions for summary judgment pursuant to Rule
121.1 The issue in this collection case is whether respondent’s
1 Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code of 1986, as amended.
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Last modified: November 10, 2007