MEMORANDUM OPINION
SWIFT, Judge:
In this collection case respondent has moved for summary judgment on the grounds that no timely raised issue of fact remains, that petitioner should not be allowed now to raise a new issue of fact, and that respondent should be entitled to judgment as a matter of law.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to...
Let's get started

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.