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KEENAN v. COMMISSIONER

Docket No. 20073-05L.

92 T.C.M. 470 (2006)

T.C. Memo. 2006-260

Robert B. Keenan v. Commissioner.

United States Tax Court.

December 6, 2006.

Attorney(s) appearing for the Case

Robert B. Keenan, pro se.

Linette B. Angelastro, for respondent.

MEMORANDUM OPINION

MARVEL, Judge:

This matter is before the Court on respondent's motion for summary judgment, filed pursuant to Rule 121,1 and to impose a penalty under section 6673.

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 years 1988 and 1990 through 1994. Petitioner resided in Camarillo...

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