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ROBERT HO v. COMMISSIONER

Dkt. No. 1291-05L.

91 T.C.M. 876 (2006)

T.C. Memo. 2006-41

Robert Ho v. Commissioner.

United States Tax Court.

March 14, 2006.

Attorney(s) appearing for the Case

Robert Ho, pro se.

Elaine T. Fuller, for respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge.

This collection review case is before the Court on respondent's Motion For Summary Judgment, as supplemented, and petitioner's Motion For Leave To File Second Amended Petition.1 As explained in detail below, we shall grant respondent's motion, as supplemented, and deny petitioner's motion.

Background

At the time that the petition was filed, and at all other...

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