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DEUTSCH v. COMMISSIONER

Dkt. No. 3583-05L.

91 T.C.M. 754 (2006)

T.C. Memo. 2006-27

Fred Deutsch v. Commissioner.

United States Tax Court.

February 15, 2006.

Attorney(s) appearing for the Case

Ira B. Stechel and John T. Morin, for petitioner.

William C. Bogardus, for respondent.

MEMORANDUM OPINION

JACOBS, Judge.

This collection review case is before the Court on respondent's motion for partial summary judgment pursuant to Rule 121.1 As explained in detail below, we shall grant respondent's motion.

Background2

On March 3, 2001, petitioner executed and submitted to respondent a Form 2848, Power of Attorney and Declaration of Representative, appointing...

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