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BRUCE v. COMMISSIONER

Dkt. No. 24303-05L.

93 T.C.M. 1400 (2007)

T.C. Memo. 2007-161

Larry Bruce v. Commissioner.

United States Tax Court.

June 21, 2007.

Attorney(s) appearing for the Case

E. Kenneth Wall, for petitioner.

Jeffrey E. Gold, for respondent.

MEMORANDUM OPINION

NIMS, Judge:

Petitioner asks this Court to review a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination). This case is before the Court on respondent's motion for summary judgment pursuant to Rule 121.

Rule 121(a) provides that either party may move for summary judgment upon all or any part of the legal issues in controversy. Full or partial summary judgment may be granted...

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