116 T.C. No. 19
UNITED STATES TAX COURT
JAMES R. KENNEDY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9544-00L. Filed April 23, 2001.
On Sept. 10, 1999, R mailed to P a notice required
by sec. 6320(a), I.R.C., concerning P’s unpaid tax
liabilities for the years 1984 through 1988. R
concedes that such notice was not mailed to P at his
last known address. On Oct. 25, 1999, R mailed to P a
final notice of intent to levy concerning P’s unpaid
tax liabilities for the years 1984 through 1988.
Although the notice of intent to levy was mailed to P
at his last known address, P failed to file a request
for an administrative hearing with the Internal Revenue
Service Office of Appeals (Appeals Office) within the
30-day period prescribed in sec. 6330, I.R.C.
Despite P’s failure to file a timely request for
an Appeals Office hearing, R granted P a so-called
equivalent hearing. On Aug. 17, 2000, R issued a
“decision letter” to P stating that R would proceed
with collection by way of levy. On Sept. 11, 2000, P
filed a petition for review with the Court.
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