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On April 19, 2000, the Appeals Office issued to petitioner a
Notice of Determination Concerning Collection Actions Under
Section 6320 and/or 6330 (notice of determination) concerning his
1984 tax liability. The determination letter informed petitioner
that he would have 30 days to contest the matter by filing a
petition with the Tax Court.
On May 17, 2000, petitioner filed a “Petition for Judicial
Review” in the U.S. District Court for the District of Idaho,
assigned docket No. CV00-266-N-EJL, challenging the notice of
determination. On December 20, 2000, the District Court issued
an order dismissing the case for lack of jurisdiction. The order
stated that petitioner would have 30 days to file a petition for
review with the Tax Court.
On January 23, 2001, petitioner instituted a second action
in the District Court by filing a “Complaint And Request For
Judicial Review Of Administrative Action”, assigned docket No.
CV01-35-N-EJL, again challenging the notice of determination. On
February 8, 2001, the District Court issued an order dismissing
the case for lack of jurisdiction. The order again stated that
petitioner would have 30 days to file a petition for review with
the Tax Court.
On March 14, 2001, the Court received and filed a Petition
For Lien Or Levy Action Under Code Sections 6320(c) Or 6330(d)
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Last modified: May 25, 2011