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.Page: 1 2 3 4 5 6 7 8 9 10 11 Next
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