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PRAGASAM v. COMMISSIONER

Dkt. No. 12636-04L.

91 T.C.M. 1077 (2006)

T.C. Memo. 2006-86

Lloyd Pragasam v. Commissioner.

United States Tax Court.

April 25, 2006.

Attorney(s) appearing for the Case

William E. Windham, for petitioner.

Alan J. Tomsic, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. Petitioner filed a petition in response to respondent's Decision Letter Concerning Equivalent Hearing under Section 6320 and/or 6330 of the Internal Revenue Code (Decision Letter).1 The issue for decision is whether the Court lacks jurisdiction under sections 6320 and 6330 with regard...

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