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CLAUDE E. v. COMMISSIONER

Dkt. No. 2203-05L.

91 T.C.M. 659 (2006)

T.C. Memo. 2006-7

Claude E. and Dana L. Salazar v. Commissioner.

United States Tax Court.

January 18, 2006.

Attorney(s) appearing for the Case

Jeremy H. Speich and Vincent L. Valenza, for petitioners.

Diana P. Hinton, for respondent.

MEMORANDUM OPINION

MARVEL, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction and to strike as to Mr. Salazar's employment tax liabilities for the quarters ended December 1998 through June 2001 on the grounds that (1) respondent never issued a notice of determination concerning a collection action under section 63301 with respect to the employment tax liabilities, and (2) the Tax...

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