Opinion
15919-19L
08-02-2021
ORDER AND DECISION
Patrick J. Urda, Judge
Pursuant to the determination of the Court as set forth in its Memorandum Opinion (T.C. Memo. 2021-78), filed June 29, 2021, it is hereby
ORDERED that respondent's motion for summary judgment, filed on September 10, 2020, is granted. It is further
ORDERED AND DECIDED that respondent may proceed with the collection action as determined in the Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 of the Internal Revenue Code, dated July 24, 2019, upon which this case this is based, with respect to the tax periods ending December 31, 2008 and December 31, 2009.