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BENJAMIN B. v. COMMISSIONER

Docket No. 8296-02L.

85 T.C.M. 771 (2003)

T.C. Memo. 2003-16

Benjamin B. and Carolyn M. Haines v. Commissioner.

United States Tax Court.

Filed January 21, 2003.

Attorney(s) appearing for the Case

Benjamin B. and Carolyn M. Haines, pro sese.

Hieu C. Nguyen, for the respondent.

MEMORANDUM OPINION

GERBER, Judge:

Respondent, in a motion filed on November 20, 2002, moved for summary judgment on the questions of whether he may proceed with collection and whether a section 66731 penalty should be imposed against petitioners. Respondent alleges that the section 6330 prerequisites have been met and that he should be allowed to proceed with collection of petitioners' assessed and outstanding tax liability....

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