William B. Meyer - Page 1

                                          115 T.C. No. 31                                              

                                     UNITED STATES TAX COURT                                           

                                WILLIAM B. MEYER, Petitioner v.                                        
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                   
                                 DIANE S. MEYER, Petitioner v.                                         
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket Nos. 2263-00L, 5001-00L.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, I.R.C., for the                                   
                  taxable years 1996 and 1997.  Ps requested an Appeals                                
                  Office hearing pursuant to sec. 6330(b), I.R.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 petitions were not filed within the 30-day period                                
                  prescribed in sec. 6330(d)(1), I.R.C.; and (2)                                       
                  consistent with Moore v. Commissioner, 114 T.C. 171                                  

            1  These cases are consolidated solely for the purpose of                                  
            disposing of the pending jurisdictional motions.                                           

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