Ronald L. Buch, Judge.
ORDER AND DECISION
Ronald L. Buch, Judge.
Pursuant to the Court's Opinion (T.C. Memo. 2022-79) issued in the above-docketed case on July 18, 2022, it is
ORDERED that the Commissioner's Motion for Summary Judgment, filed December 13, 2021, 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 January 15, 2021, upon which this case is based, are sustained.