T.C. Memo. 2003-7
UNITED STATES TAX COURT
JOHN J. GREEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13977-01L. Filed January 8, 2003.
P filed a timely petition for judicial review
pursuant to sec. 6330(d)(1)(A), I.R.C., in response to
a notice of determination by R to proceed with
collection of assessed tax liabilities for 1996. P
filed a motion to dismiss for lack of jurisdiction.
Held: We do not look behind a notice of
determination to decide whether the determination is
valid for jurisdictional purposes. The notice of
determination is valid on its face, and we have
jurisdiction pursuant to sec. 6330(d)(1)(A), I.R.C.
John J. Green, pro se.
Robert T. Little, for respondent.
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