T.C. Memo. 2007-242
UNITED STATES TAX COURT
KEVIN F. FOLEY AND SHULA K. FOLEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11602-06L. Filed August 23, 2007.
Mark A Pridgeon, for petitioners.
Trent D. Usitalo, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: This matter is before us under Rule 121 on
the parties’ cross-motions for summary judgment. The underlying
issue in this collection case is whether respondent’s Appeals
Office abused its discretion in sustaining respondent’s proposed
levy action against petitioners’ residence.
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Last modified: November 10, 2007