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FONG v. COMMISSIONER

Dkt. No. 18124-05LA.

93 T.C.M. 1299 (2007)

T.C. Memo. 2007-137

Edward Fong v. Commissioner.

United States Tax Court.

May 31, 2007.

Attorney(s) appearing for the Case

Edward Fong, pro se.

Laura Buckley and Mary Schewatz, for respondent.

MEMORANDUM OPINION

MARVEL, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent alleges that we do not have jurisdiction under section 6330(d)(1)1 to review respondent's decision to proceed with a levy action to collect petitioner's unpaid tax liability for 2001. Petitioner filed a response in opposition to the motion.

Background

Petitioner resided...

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