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issued to his address of record and he had not
petitioned the tax court as directed. The taxpayer had
previously requested a transcript of account and was
promised one at the conference. A transcript of
account was provided to the taxpayer on 10/5/2001.
* * * * * * *
A review of the case history indicates a valid
assessment was made, notice and demand was provided and
a neglect or refusal to pay occurred. * * *
* * * * * * *
The Federal Tax Lien is sustained. Proper
administrative procedures were followed by Service
personnel. This recommendation balances the need for
efficient tax administration.
In response to this notice, petitioner timely filed a
petition with the Tax Court for judicial review pursuant to
section 6330(d)(1)(A). At the time the petition was filed in
this case, petitioner resided in Steger, Illinois.
On the same day petitioner filed the petition, he submitted
a “MOTION THAT THE TAX COURT DECLARE INVALID THE IRS
‘DETERMINATION’ AT ISSUE”. As grounds for this motion,
petitioner asserted that “the appeals officer issued the
‘Determination’ without conducting the CDP [collection due
process] hearing in accordance with the law.” This motion was
filed by the Court as a motion to dismiss for lack of
jurisdiction.
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Last modified: May 25, 2011