MEMORANDUM OPINION
MARVEL, Judge:
This matter is before the Court on respondent's motion for summary judgment filed under Rule 121.
Background
This is an appeal from respondent's determination to uphold the validity of a notice of Federal tax lien filed with respect to petitioners' 2001 unpaid income tax liability. Petitioners resided in Henrietta, New York, when the petition was filed.
Petitioners...
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