Opinion
13202-19L
07-28-2022
ALEJANDRO SERNA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Patrick J. Urda Judge
Pursuant to the determination of the Court, as set forth in its Memorandum Opinion (T.C. Memo. 2022-66), filed June 27, 2022, it is
ORDERED that the Commissioner's motion for summary judgment, filed September 8, 2020, is granted. It is further
ORDERED and DECIDED that the determination set forth in the Notice of Determination Concerning Collection Actions Under IRC Sections 6320 and/or 6330 of the Internal Revenue Code, dated June 12, 2019, upon which is this case is based, is sustained.