MEMORANDUM OPINION
LARO, Judge:
Petitioner, while residing in Santa Maria, California, petitioned the Court under section 6330(d) to review respondent's filing of a notice of lien under section 6323. Respondent filed the lien on petitioner's property to secure petitioner's payment of his 1994 Federal income tax liability of $3,385.56. Currently, the case is before the Court on respondent's motion for summary judgment under Rule 121 and to impose a penalty...
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