Opinion
7726-20L
03-31-2022
ORDER AND DECISION
Albert G. Lauber Judge
Pursuant to the Court's Opinion (T.C. Memo. 2022-26) issued in the above docketed case on March 29, 2022, it is
ORDERED that respondent's Motion for Summary Judgment, filed on October 5, 2021, is granted. It is further
ORDERED AND DECIDED that the determinations set forth in the Notice of Determination Concerning Collection Actions Under IRC Sections 6320 or 6330 of the Internal Revenue Code, dated February 25, 2020, upon which this case is based, are sustained. It is further
ORDERED AND DECIDED that pursuant to I.R.C. § 6673(a), petitioner shall pay a penalty to the United States in the amount of $2,000.