T.C. Memo. 2005-96
UNITED STATES TAX COURT
MYONG SOO KIM AND SUNG ME HWANG, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17168-02L. Filed May 3, 2005.
Myong Soo Kim and Sung Me Hwang, pro sese.
Lisa M. Oshiro, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge: This matter is before the Court on
respondent’s motion to dismiss for lack of jurisdiction, as
supplemented, on the ground that respondent issued an invalid
notice of determination concerning a collection action under
section 6330.1
1Unless otherwise indicated, all section references are to
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