114 T.C. No. 30
UNITED STATES TAX COURT
LUCIELLE J. OFFILER, A.K.A. LUCILLE OFFILER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16389-99. Filed June 19, 2000.
On Feb. 1, 1999, R mailed to P a Final Notice-
Notice of Intent to Levy and Notice of Your Right to a
Hearing, as required by sec. 6330, I.R.C. The notice
pertained to P’s unpaid income tax liabilities for 1994
and 1995. Sec. 6330(a), I.R.C., requires only one such
notice for the tax period for which R is attempting to
collect tax. Under sec. 6330, I.R.C., P had 30 days in
which to request a hearing before the IRS Office of
Appeals. P did not request a hearing within 30 days of
Feb. 1, 1999. Had a timely request for hearing been
made, sec. 6330(c), I.R.C., provides for a hearing and
“determination” by Appeals regarding the propriety of
the proposed levy. Sec. 6330(d), I.R.C. permits an
appeal of such a determination to this Court within 30
days of the date of such determination. Because P
failed to make a timely request for hearing pursuant to
sec. 6330, I.R.C., R was not required to, and did not,
make a “determination” within the meaning of sec. 6330,
I.R.C.
Page: 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011