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ATL. PAC. MGMT. GRP., LLC v. COMMISSIONER

Docket No. 8412-18.

152 T.C. 330 (2019)

ATLANTIC PACIFIC MANAGEMENT GROUP, LLC, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 20, 2019.

Attorney(s) appearing for the Case

Frank Agostino and Phillip J. Colasanto , for petitioner.

Michael J. De Matos , for respondent.

OPINION

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent argues that no notice of determination was sent to petitioner under sections 6320 and 63301 for tax years 2014 and 2015 and, therefore, the necessary prerequisite—i.e., a notice...

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