MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, Special Trial Judge:
This collection review case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction. Respondent moves to dismiss on the ground that no notice of determination was sent to petitioner for 2000 and 2001, the taxable years in issue. In contrast, petitioner contends that no valid final notice of intent to levy was ever sent to him at his last known address, nor did he receive...
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