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BLOSSER v. COMMISSIONER

Dkt. No. 9350-06L.

94 T.C.M. 414 (2007)

T.C. Memo. 2007-323

Judy Hedrick Blosser v. Commissioner.

United States Tax Court.

October 29, 2007.

Attorney(s) appearing for the Case

Brian Carl Bernhardt, for petitioner.

Veena Luthra, for respondent.

MEMORANDUM OPINION

GOEKE, Judge.

This matter is before the Court on the parties' cross-motions for summary judgment pursuant to Rule 121.1 The issue in this collection case is whether respondent's Appeals Office abused its discretion in sustaining respondent's proposed levy action against petitioner to collect income tax liabilities for the taxable years 1994, 1995, and 1996 and denying petitioner's request for alternative collection...

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