Opinion
12350-20L
06-01-2023
JOSEPH WILLIAM KOVACH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Albert G. Lauber Judge
On October 3, 2022, respondent filed a Motion for Partial Summary Judgment. On December 21, 2022, respondent filed a First Supplement to Motion for Partial Summary Judgment, whereby he requested judgment in his favor on all issues not covered by his original Motion. Pursuant to the Court's Opinion (T.C. Memo. 2023-67) issued in the above docketed case on May 30, 2023, it is
ORDERED that respondent's Motion for Partial Summary Judgment filed October 3, 2022, as supplemented on December 21, 2022, is granted. It is further
ORDERED AND DECIDED that the determination set forth in the Notice of Determination Concerning Collection Actions under IRC 6320 or 6330 of the Internal Revenue Code, dated September 15, 2020, upon which this case is based, is sustained.