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LISTER v. COMMISSIONER

Docket No. 9173-02L.

85 T.C.M. 774 (2003)

T.C. Memo. 2003-17

Jan Lister v. Commissioner.

United States Tax Court.

Filed January 21, 2003.

Attorney(s) appearing for the Case

Jan Lister, pro se.

Donald E. Edwards, for the respondent.

MEMORANDUM OPINION

MARVEL, Judge:

This matter is before the Court on respondent's motion for summary judgment, filed pursuant to Rule 121, and to impose a penalty under section 6673.1 Respondent contends that there is no dispute as to any material fact regarding this levy action and that respondent's determination to proceed with collection of petitioner's outstanding Federal income tax liabilities for 1993 and 1994 by levy should...

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