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PREVO v. COMMISSIONER

Docket No. 5805-04L.

123 T.C. 326 (2004)

123 T.C. No. 21

CLARA L. PREVO, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 14, 2004.

Attorney(s) appearing for the Case

Clara L. Prevo, pro se.

Brianna Basaraba Taylor, for respondent.

OPINION

GERBER, Chief Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent's motion presents an issue of first impression regarding the application of the automatic stay imposed under 11 U.S.C. section 362(a)(8) (2000) in a collection review proceeding brought in this Court pursuant to section 6320.1 As discussed in detail below, we shall grant respondent's motion...

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