- 2 -
MEMORANDUM OPINION
NIMS, Judge: Petitioner asks this Court to review a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330 (notice of determination). This case is before
the Court on respondent’s motion for summary judgment pursuant to
Rule 121.
Rule 121(a) provides that either party may move for summary
judgment upon all or any part of the legal issues in controversy.
Full or partial summary judgment may be granted only if it is
demonstrated that no genuine issue exists as to any material
fact, and a decision may be entered as a matter of law. Rule
121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520
(1992), affd. 17 F.3d 965 (7th Cir. 1994).
We conclude that there is no genuine issue as to any
material fact and that a decision may be rendered as a matter of
law.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the tax year
at issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
At the time he filed the petition in this case, petitioner
resided in Lumberton, North Carolina.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: November 10, 2007