Legal Opinion

Bruce v. Comm'r

United States Tax Court

Decided June 21, 2007No. 24303-05LUnpublished

Respondent filed a Notice of Federal Tax Lien against P for the unpaid balance of his Federal income taxes for 2003. After notice to P and a hearing, R's settlement officer issued a notice of determination upholding the proposed collection action. R moved for summary judgment on all issues. Held: R's motion for summary judgment will be granted. R may proceed with collection by lien.

1Opinion of the Court

LARRY BRUCE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bruce v. Comm'r

No. 24303-05L

United States Tax Court

T.C. Memo 2007-161; 2007 Tax Ct. Memo LEXIS 164; 93 T.C.M. (CCH) 1400;

June 21, 2007, Filed

Respondent filed a Notice of Federal Tax Lien against P for the unpaid balance of his Federal income taxes for 2003. After notice to P and a hearing, R's settlement officer issued a notice of determination upholding the proposed collection action. R moved for summary judgment on all issues.

Held: R's motion for summary judgment will be granted. R may proceed with collection by lien.

E.…

2Cases cited16 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  4. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  5. Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988

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