T.C. Memo. 2006-7
UNITED STATES TAX COURT
CLAUDE E. AND DANA L. SALAZAR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2203-05L. Filed January 18, 2006.
Jeremy H. Speich and Vincent L. Valenza, for petitioners.
Diana P. Hinton, for respondent.
MEMORANDUM OPINION
MARVEL, Judge: This matter is before the Court on
respondent’s motion to dismiss for lack of jurisdiction and to
strike as to Mr. Salazar’s employment tax liabilities for the
quarters ended December 1998 through June 2001 on the grounds
that (1) respondent never issued a notice of determination
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