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certified mail a Notice Of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330. Respondent mailed the
notice to petitioner at the Amherst address. The notice of
determination informed petitioner that if he wanted to dispute
respondent’s determination in court, then he must file a petition
with the Tax Court “within 30 days from the date of this letter.”
On February 7, 2002, the Court received and filed a Petition
for Lien or Levy Action Under Code Sections 6320(c) or 6330(d).
The petition arrived at the Court in a properly addressed
envelope bearing a U.S. Postal Service postmark date of January
11, 2002. The petition, as well as the envelope in which the
petition was mailed, lists petitioner’s address as the Amherst
address.
As indicated, respondent moved to dismiss the petition for
lack of jurisdiction on the ground the petition was not timely
filed. Petitioner filed an objection to respondent’s motion to
dismiss. Although the objection does not list petitioner’s
address, the envelope in which the objection was mailed to the
Court lists the Amherst address.
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Last modified: May 25, 2011