MEMORANDUM OPINION
ARMEN, Special Trial Judge:
This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction, as supplemented. As explained in detail below, we shall grant respondent's motion in part and deny it in part.
Background
On July 13, 2001, respondent issued to petitioners separate Notices of Determination Concerning Collections Action(s) Under Section 6320 and/or 6330 with regard to their unpaid...
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