117 T.C. No. 6
UNITED STATES TAX COURT
LEONARD PARKER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2712-00L. Filed August 21, 2001.
Before the effective date of secs. 6320 and 6330,
I.R.C. (the effective date), R filed Federal income tax
liens against certain property owned by P. After the
effective date, R notified P under sec. 6331, I.R.C.,
that R intended to levy upon the property and offered
to P the administrative hearing required by sec. 6330,
I.R.C. R later issued to P a notice of determination
as to the proposed levy, and P petitioned the Court to
review that determination. R asserts that the Court
lacks jurisdiction to review the determination because
it involves property against which R filed a lien
before the effective date.
Held: Sec. 6330(d), I.R.C., grants this Court
jurisdiction to review R’s determination. Sec. 6330,
I.R.C., is effective for collection actions initiated
after the effective date and, for purposes of that
section, R initiated the collection action against P
when R issued to P a notice under sec. 6331, I.R.C.,
stating that R intended to levy upon P’s property.
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