Opinion
17637-23L
09-16-2024
MOMOLU SIRLEAF, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Tamara W. Ashford, Judge.
This case is currently calendared for trial at the Session of the Court commencing on November 18, 2024, in Philadelphia, Pennsylvania. On September 12, 2024, respondent filed an unopposed Motion for Summary Judgment, contending that no genuine dispute exists as to any material fact and that the determination of the Internal Revenue Service Independent Office of Appeals approving a notice of intent to levy with respect to petitioner's unpaid federal income tax liabilities for the 2009,2010, and 2011 taxable years should be sustained as a matter of law. Upon due consideration, it is hereby
ORDERED that respondent's Motion for Summary Judgment, filed September 12, 2024, is granted. It is further
ORDERED AND DECIDED that respondent may proceed with the collection action with respect to petitioner's unpaid federal income tax liabilities for the 2009, 2010,and 2011 taxable years, as described in the Notice of Determination Concerning Collection Action(s) Under Sections 6320 or 6330, dated October 20, 2023.