Arthur Dalton, Jr. and Beverly Dalton v. Commissioner

SUPPLEMENTAL OPINION

Wells, Judge:

This case is before the Court on petitioners’ motion for summary judgment pursuant to Rule 121. Respondent filed a response to petitioners’ motion for summary judgment and subsequently filed a second motion for summary judgment. The instant proceeding arises from a petition filed in response to Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 issued separately to each petitioner. The issues to be decided are: (1) Whether we have jurisdiction to decide the instant matter; and (2) if so, whether respondent abused his…