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OPINION
COHEN, Judge: This matter is before the Court on
respondent’s motion to dismiss for lack of jurisdiction on the
ground that the petition was not filed within the time prescribed
by section 6330(d)(1) or section 7502. Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect for the years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
At the time the petition in this case was filed, petitioner
was a resident of Rockwall, Texas.
On January 27, 1999, a Final Notice - Notice of Intent to
Levy and Notice of Your Right to a Hearing (CDP notice) was
mailed to petitioner with respect to unpaid Federal income taxes,
interest, and penalties for 1992 through 1994. The CDP notice
explained petitioner’s right to a Collection Due Process hearing
(CDP hearing) and provided him with a copy of Form 12153, Request
for a Collection Due Process Hearing. Petitioner requested and
was granted a hearing. On July 29, 1999, the Internal Revenue
Service Office of Appeals (Appeals) issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330. In that notice, it was determined that the proposed
levy actions satisfied the requirements of sections 6631 and 6321
and the applicable administrative procedures. On August 10,
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