MEMORANDUM OPINION
GALE, Judge.
This case is before us on respondent's motion for summary judgment on the question of whether he may proceed with collection with respect to certain unpaid taxes of petitioner for the taxable years 1995, 1996, and 1997. For reasons set forth below, we shall grant respondent's motion.
Summary judgment is intended to expedite litigation and avoid unnecessary and expensive trials. Fla. Peach Corp. v. Commissioner<...
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