Felix and Liliana P. Prakasam - Page 11

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               We shall grant respondent’s motions to dismiss for lack of             
          jurisdiction as to 1995 and 1996 because the petitions were not             
          filed in response to notices of determination sufficient to                 
          confer jurisdiction on the Court under sections 6320(c) and                 
          6330(d)(1).                                                                 
               To reflect the foregoing,                                              

                                             An appropriate order of                  
                                        dismissal for lack of jurisdiction            
                                        will be entered in docket No.                 
                                        12136-04L.                                    
                                             An appropriate order and order           
                                        of dismissal for lack of                      
                                        jurisdiction will be entered in               
                                        docket No. 12212-04L.                         




















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