Opinion
20468-21L
09-15-2023
PIPER TRUCKING & LEASING, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND ORDER AND DECISION
Maurice B. Foley, Judge
Pursuant to the determination of the Court as set forth in its Opinion (161 T.C. No. 3), filed September 14, 2023, it is
ORDERED that petitioner's Motion for Summary Judgment, filed December 5, 2022, is denied. It is further
ORDERED that respondent's Motion for Summary Judgment, filed November 9, 2022, is granted. It is further
ORDERED AND DECIDED that respondent may proceed with the collection action as determined in the Notice of Determination relating to 2015.