T.C. Memo. 2002-264
UNITED STATES TAX COURT
RONALD W. NELSON, JR. AND JENNIFER J. NELSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5323-02L. Filed October 10, 2002.
Ronald W. Nelson, Jr. and Jennifer J. Nelson, pro sese.
Karen Nicholson Sommers and Scott A. Hovey, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent’s Motion To Dismiss For Lack Of Jurisdiction And To
Strike, as supplemented. Respondent moves that this case,
insofar as it relates to a decision letter concerning equivalent
hearing, be dismissed for lack of jurisdiction on the ground that
“no Notice of Determination under I.R.C. � 6320 or � 6330 was
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