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William B. Meyer, petitioner v. Commissioner of Internal Revenue, respondent / Diane S. Meyer, petitioner v. Commissioner of Internal Revenue, respondent

Docket Nos. 2263-GOL, 5001-OOL.1

Filed November 7, 2000.

R issued final notices of intent to levy to Ps. The notices requested payment of frivolous return penalties imposed under sec. 6702, LR.C., for the taxable years 1996 and 1997. Ps requested an Appeals Office hearing pursuant to sec. 6330(b), LR.C. On Jan. 13, 2000, prior to conducting an Appeals Office hearing, R issued determination letters to Ps stating that R would proceed with collection. On Feb. 23, 2000, the Court received and filed petitions for review of R's determination letters that Ps had mailed to the Court on Feb. 15, 2000. R filed motions to dismiss the petitions for lack of jurisdiction on the grounds: (1) The ...

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