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CALAFATI v. COMMISSIONER

Docket No. 17529-03L.

127 T.C. 219 (2006)

127 T.C. No. 16

DOMINIC CALAFATI, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 26, 2006.

Attorney(s) appearing for the Case

David S. Brady, for petitioner.

Jack T. Anagnostis, for respondent.

OPINION

MARVEL, Judge:

This matter is before the Court on petitioner's motion for summary judgment filed pursuant to Rule 121.1

Background

This is an appeal from respondent's determination upholding the proposed use of a levy to collect petitioner's unpaid Federal income tax liability for 1998. The only issues petitioner raises are whether, pursuant to...

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