MEMORANDUM OPINION
VASQUEZ, Judge:
This case is before the Court on respondent's motion to dismiss for failure to state a claim upon which relief could be granted.
Background
On February 5, 2004, respondent sent petitioner a notice of intent to levy and right to a hearing regarding income taxes owed for 2001.
On June 3, 2004, respondent sent petitioner a notice of intent to levy and right to a hearing regarding income taxes...
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