Opinion
15761-21L
07-28-2023
MICHAEL J. STEVENS & ALEXIS M. STEVENS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Travis A. Greaves, Judge.
Pursuant to the determination of this Court, as set forth in its Memorandum Opinion (T.C. Memo. 2023-94), filed July 24, 2023, it is
ORDERED that respondent's Motion for Summary Judgment filed November 4, 2021, is granted. It is further
ORDERED and DECIDED that respondent may proceed with collection as determined in the Notice of Determination dated April 2, 2021, a copy of which is attached to the petition.