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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