Dwight Schwersensky, (2006)
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Dwight Schwersensky, (2006)
T.C. Memo. 2006-178
UNITED STATES TAX COURT DWIGHT SCHWERSENSKY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17983-03L. Filed August 24, 2006.Dwight Schwersensky, pro se.Sylvia L. Shaughnessy, for respondent.MEMORANDUM OPINION GALE, Judge: This case is before the Court on respondent's motion for summary judgment on the issue of whether he may proceed by levy to collect unpaid income taxes for petitioner's 2000 tax year. Respondent's motion also seeks a penalty under section 6673.1 A hearing was held thereon. For the reasons set forth below, we shall grant respondent's motion.Summary judgment is intended to expedite litigation and avoid unnecessary and expensive trials. Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). Summary judgment may be granted where there is no genuine issue of material fact and a decision may be rendered as a matter of law. Rule 121(a) and (b). The moving party bears the burden of proving that there is no genuine issue of material fact, and factual inferences are viewed in a light most favorable to the nonmoving party. Craig v. Commissioner, 119 T.C. 252, 260 (2002); Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v. ...See the full content of this document
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