Opinion
12871-18L
11-02-2021
Ronald M. Goldberg Petitioner v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Elizabeth Crewson Paris, Judge
Pursuant to the Court's October 19, 2021, Memorandum Opinion (T.C. Memo 2021-119) it is
ORDERED that respondent's motion for summary judgment filed with the Court on August 21, 2019 is granted. It is further
ORDERED that petitioner's motion for summary judgment, filed on September 11, 2019, is denied. It is further
ORDERED and DECIDED that respondent may proceed with collection action as determined in the Notice of Determination Concerning Collection Action(s) under Section 6320 and/or 6330, dated June 1, 2018, for petitioner's 1998 and 2000 tax years.