Opinion
4887-20L
10-12-2021
Michael D. Westbrook & Kristy A. Westbrook Petitioners v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
MARK V. HOLMES JUDGE
This case is on the Court's October 25, 2021 San Francisco, California trial calendar and is an appeal from respondent's notice of determination. On August 25, 2021 respondent moved for summary judgment. We gave petitioners an opportunity to respond and they did so on September 23 with a notice that they did not object.
It is therefore
ORDERED that respondent's August 25, 2021 motion for summary judgment is granted. It is also
ORDERED and DECIDED that respondent may proceed with the collection of petitioners' federal income-tax liabilities for the tax years 2015 and 2016 as described in the Notice of Determination Concerning Collection Action(s) under Section 6320 and/or 6330, dated February 25, 2020.
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