119 T.C. No. 22
UNITED STATES TAX COURT
JOSEPH W. DORN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6240-00L. Filed December 30, 2002.
To collect petitioner’s (P) unpaid income tax
liabilities for 1987-89, respondent (R) issued a notice
of levy to a fund in which petitioner maintained
accounts and issued to P a notice of jeopardy levy and
right to appeal. See sec. 6330(f), I.R.C. P requested
and R held a hearing under sec. 6330(b), I.R.C. After
the hearing, R determined that imposition of a jeopardy
levy was appropriate. P filed a petition under sec.
6330(d), I.R.C., seeking judicial review of that
determination.
Held: The Tax Court has jurisdiction under sec.
6330(d), I.R.C., to review R’s determination that R’s
use of a jeopardy levy was appropriate.
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