Opinion
9326-22L
04-10-2024
ROBERT A. ZIENKOWSKI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Albert G. Lauber Judge
Pursuant to the Court's Opinion (T.C. Memo. 2024-39) issued in the above-docketed case on April 8, 2024, it is
ORDERED that respondent's Motion for Summary Judgment, filed August 31, 2023, is granted. It is further
ORDERED AND DECIDED that the determinations set forth in the Notice of Determination Concerning Collection Actions under IRC Sections 6320 or 6330 of the Internal Revenue Code, dated March 31, 2022, upon which this case is based, are sustained.