T.C. Memo. 2000-163
UNITED STATES TAX COURT
ROLAND D. VAN FOSSEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11269-99L. Filed May 18, 2000.
Roland D. Van Fossen, pro se.
Usha Ravi, for respondent.
MEMORANDUM OPINION
GERBER, Judge: Petitioner filed a petition seeking relief
from respondent’s decision to pursue collection activity.
Petitioner is seeking solely to challenge the underlying
deficiencies. Respondent moved to dismiss this proceeding for
lack of jurisdiction on the ground that petitioner is precluded
from questioning the underlying deficiency determinations because
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