Opinion
17918-21SL
11-17-2022
ALLA SALIY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo, Chief Special Trial Judge
This I.R.C. section 6330(d) case is before the Court on respondent's motion for summary judgment, filed February 24, 2022. Respondent's motion was heard in Boston, Massachusetts, on November 9, 2022. Counsel for respondent appeared and argued in support of the motion. There was no appearance by or on behalf of petitioner.
Giving due regard to the representations contained in respondent's motion and taking into account statements made by respondent's counsel at the hearing, we are satisfied that there are no genuine issues of fact in dispute in this case and further that respondent is entitled to decision as a matter of law. The motion shows that in all respects respondent has proceeded as required in section 6330, and nothing submitted by petitioner suggests, much less establishes otherwise. That being so, it is
ORDERD that respondent's motion is granted. It is further
ORDERED that respondent may proceed with collection as provided in the Notice of Determination, dated April 15, 2021, a copy of which is attached to the petition.