T.C. Memo. 2007-32
UNITED STATES TAX COURT
DAVID BUFFANO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11281-06L. Filed February 8, 2007.
R filed a motion to dismiss P’s collection review
action directed at R’s effort to levy upon P’s
property. R argued lack of jurisdiction due to P’s
untimely request for an Appeals Office hearing. P
argued that he did not timely receive notice of R’s
intent to levy.
1. Held: R’s motion to dismiss for lack of
jurisdiction on the ground that P made an untimely
hearing request will be denied.
2. Held, further: No valid final notice of
intent to levy was issued because the notice was not
mailed to P’s last known address.
3. Held, further: This case will be dismissed
for lack of jurisdiction because no valid final notice
of intent to levy was issued to P.
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