Opinion
26587-21L
08-29-2023
ORDER AND DECISION
Adam B. Landy Special Trial Judge
On November 16, 2022, the Commissioner filed a Motion for Summary Judgment. Pursuant to the determination of this Court as set forth in its Memorandum Opinion (T.C. Memo. 2023-110) filed August 28, 2023, it is
ORDERED that the Commissioner's Motion for Summary Judgment filed November 16, 2022, is granted. It is further
ORDERED AND DECIDED that the determinations set forth in the Notice of Determination Concerning Collection Actions under IRC 6320 or 6330 of the Internal Revenue Code, dated June 16, 2021, upon which this case is based, are sustained.