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.Page: 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007