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MAGANA v. COMMISSIONER

Docket No. 10306-00L.

118 T.C. 488 (2002)

118 T.C. No. 30

RAYMOND B. MAGANA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 31, 2002.

Attorney(s) appearing for the Case

Paul H. Durham, for petitioner.

William F. Castor, for respondent.

OPINION

SWIFT, Judge:

This matter is before us on respondent's motion under Rule 121 for summary judgment. Petitioner challenges respondent's Appeals Office determination sustaining the filing of Federal tax liens relating to petitioner's $472,532 assessed and unpaid Federal income tax deficiency for 1980.

Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to...

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