T.C. Memo. 2007-194
UNITED STATES TAX COURT
RAGNHILD ANNE WESTBY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15093-06L. Filed July 19, 2007.
Ragnhild Anne Westby, pro se.
John C. Schmittdiel, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: In this collection case respondent has moved
for summary judgment on the grounds that no timely raised issue
of fact remains, that petitioner should not be allowed now to
raise a new issue of fact, and that respondent should be entitled
to judgment as a matter of law.
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Last modified: November 10, 2007