T.C. Memo. 2002-161
UNITED STATES TAX COURT
THOMAS & IRIS TILLEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 400-01L. Filed June 25, 2002.
Knox Kent Lively III, for petitioners.
Blake Ferguson and J. Craig Young, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case comes before the
Court on respondent’s Motion To Dismiss For Lack Of Jurisdiction,
and on petitioners’ cross-motion to dismiss. Section references
are to the Internal Revenue Code as amended.
On May 26, 1999, the Internal Revenue Service Appeals Office
in Greensboro, North Carolina, issued two separate Notices of
Determination Concerning Collection Action(s) Under Section 6320
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Last modified: May 25, 2011