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ORUM v. COMMISSIONER

Docket No. 18317-02L.

123 T.C. 1 (2004)

123 T.C. No. 1

KEITH AND CHERIE ORUM, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 1, 2004.

Attorney(s) appearing for the Case

Keith Orum, pro se.

Sean R. Gannon, for respondent.

OPINION

HAINES, Judge:

Respondent sent petitioner Keith Orum (Mr. Orum) and petitioner Cherie Orum (Mrs. Orum) a Decision Letter Concerning Equivalent Hearing Under Section 6320 and/or 6330 (decision letter) for 1998 and a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) for 1999.

The issues for decision are: (1) Whether the Court lacks jurisdiction under section 6330(d)(1)

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