MEMORANDUM OPINION
GERBER, Judge:
Respondent, in a motion filed on November 6, 2003, moved for summary judgment on the question of whether respondent may proceed with collection of Federal income tax assessed against petitioner. Petitioner, on November 14, 2003, filed a cross-motion for summary judgment on the question of whether this case should be remanded to respondent's Appeals Office for a recorded administrative hearing. Petitioner objects to respondent...
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