MEMORANDUM OPINION
PAJAK, Special Trial Judge.
This case comes before the Court on respondent's Motion To Dismiss For Lack Of Jurisdiction, and on petitioners' cross-motion to dismiss. Section references are to the Internal Revenue Code as amended.
On May 26, 1999, the Internal Revenue Service Appeals Office in Greensboro, North Carolina, issued two separate Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 ...
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