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MARS'S CONTRACTORS, INC. v. COMMISSIONER

Dkt. No. 11131-05L.

91 T.C.M. 1128 (2006)

T.C. Memo. 2006-94

Mars's Contractors, Inc., a Florida Corporation v. Commissioner.

United States Tax Court.

May 3, 2006.

Attorney(s) appearing for the Case

Vera Elaine Gilford, for petitioner.

Justin Campolieta, for respondent.

MEMORANDUM OPINION

GOEKE, Judge.

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. This case involves respondent's determination that a collection action is appropriate under sections 6320 and 6330.1

Respondent argues that the underlying tax liability in question is employment taxes and that this Court's lack of jurisdiction over...

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