OPINION
SWIFT, Judge:
This matter is before us in this collection action under Rule 121 on the parties' cross-motions for summary judgment as to both respondent's notice of Federal tax lien filing (NFTL) and respondent's notice of intent to make a second levy.
Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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