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DORRA v. COMMISSIONER

Docket No. 4437-03L.

87 T.C.M. 822 (2004)

T.C. Memo. 2004-16

Ariel J. Dorra v. Commissioner.

United States Tax Court.

Filed January 26, 2004.

Attorney(s) appearing for the Case

Ariel J. Dorra, pro se.

Leonard T. Provenzale, for the respondent.

MEMORANDUM OPINION

GERBER, Judge.

Respondent in a motion filed on August 12, 2003, moves for summary judgment on the question of whether collection may proceed in accord with the Notice of Determination Concerning Collection Actions(s) Under Section 6320 and/or 6330 (notice of determination) sent to petitioner February 20, 2003. Petitioner contends that he did not have a "hearing" within the meaning of section 6320(b) or 6330(b).1

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