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Action(s) Under Section 6320 and/or 6330.1 On March 28, 2002,
the Court received and filed a Petition for Lien or Levy Action
Under Code Sections 6320(c) or 6330(d).2 The petition lists the
years in dispute as 1991 through 1996.
As indicated, respondent moved to dismiss for lack of
jurisdiction and to strike as to the taxable years 1991 and 1992.
Respondent contends that the Court lacks jurisdiction with regard
to 1991 and 1992 on the ground that respondent has not issued to
petitioner a notice of determination with regard to those years.
Respondent avers that the notice of determination dated February
19, 2002, on which the petition is based, pertains only to the
taxable years 1993 through 1996. Petitioner filed an objection
to respondent’s motion, attaching to her objection copies of the
notices of levy for 1991 and 1992 that respondent served on the
City of Philadelphia and Corestates Bank (described above).
This matter was called for hearing at the Court’s motions
session held in Washington, D.C. Counsel for respondent appeared
at the hearing and offered argument in support of the motion to
dismiss. There was no appearance by or on behalf of petitioner.
Following the hearing, respondent filed a supplement to his
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended.
2 The petition arrived at the Court in a properly addressed
envelope bearing a timely U.S. Postal Service postmark date of
Mar. 19, 2002.
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Last modified: May 25, 2011