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PARKER II v. COMMISSIONER

Docket No. 8214-04L.

90 T.C.M. 349 (2005)

T.C. Memo. 2005-231

Carey K. Parker II. v. Commissioner.

United States Tax Court.

October 3, 2005.

Attorney(s) appearing for the Case

Carey K. Parker II, pro se.

Marty J. Dama, for respondent.

MEMORANDUM OPINION

VASQUEZ, Judge:

Respondent sent petitioner a Decision Letter Concerning Equivalent Hearing Under Section 6320 and/or 63301 for 1994, 1995, 1996, and 1997. The issue for decision is whether the Court lacks jurisdiction under section 6330(d)(1) with regard to the years in issue.

Background

At the time he filed the petition, petitioner resided in Arlington, Texas. Since at least 2000,...

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