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SMITH v. COMMISSIONER

Dkt. No. 4675-06L.

94 T.C.M. 150 (2007)

T.C. Memo. 2007-221

Craig I. Smith v. Commissioner.

United States Tax Court.

August 9, 2007.

Attorney(s) appearing for the Case

Craig I. Smith and Mary Lou Smith, pro sese.

Anita A. Gill, for respondent.

MEMORANDUM OPINION

JACOBS, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. Petitioners filed a timely request for a hearing pursuant to section 6330 but withdrew it after entering into an installment agreement with respondent. The issues for decision are: (1) Whether petitioners' request for a hearing pursuant to section 63301 entitled petitioners to a section 6330 hearing upon...

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