T.C. Memo. 2007-221
UNITED STATES TAX COURT
CRAIG I. SMITH AND MARY LOU SMITH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4675-06L. Filed August 9, 2007.
Craig I. Smith and Mary Lou Smith, pro sese.
Anita A. Gill, for respondent.
MEMORANDUM OPINION
JACOBS, Judge: This matter is before the Court on
respondent’s motion to dismiss for lack of jurisdiction.
Petitioners filed a timely request for a hearing pursuant to
section 6330 but withdrew it after entering into an installment
agreement with respondent. The issues for decision are: (1)
Whether petitioners’ request for a hearing pursuant to section
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Last modified: November 10, 2007