Leonard Parker - Page 1

                                   117 T.C. No. 6                                     

                               UNITED STATES TAX COURT                                

                            LEONARD PARKER, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2712-00L.               Filed August 21, 2001.              

                    Before the effective date of secs. 6320 and 6330,                 
               I.R.C. (the effective date), R filed Federal income tax                
               liens against certain property owned by P.  After the                  
               effective date, R notified P under sec. 6331, I.R.C.,                  
               that R intended to levy upon the property and offered                  
               to P the administrative hearing required by sec. 6330,                 
               I.R.C.  R later issued to P a notice of determination                  
               as to the proposed levy, and P petitioned the Court to                 
               review that determination.  R asserts that the Court                   
               lacks jurisdiction to review the determination because                 
               it involves property against which R filed a lien                      
               before the effective date.                                             
                    Held:  Sec. 6330(d), I.R.C., grants this Court                    
               jurisdiction to review R’s determination.  Sec. 6330,                  
               I.R.C., is effective for collection actions initiated                  
               after the effective date and, for purposes of that                     
               section, R initiated the collection action against P                   
               when R issued to P a notice under sec. 6331, I.R.C.,                   
               stating that R intended to levy upon P’s property.                     

Page:   1  2  3  4  5  6  7  Next

Last modified: May 25, 2011