MEMORANDUM OPINION
RUWE, Judge:
This case is before the Court on respondent's motion for summary judgment and to impose a penalty under section 6673.
Background
Respondent sent to petitioner a Final Notice - Notice of Intent to Levy and Notice of Your Right to a Hearing and a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 with respect to unpaid tax that had previously been...
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