Paul L. Hickey and Nellida F. Hickey - Page 2

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               On July 13, 2001, respondent issued to petitioners separate            
          Notices of Determination Concerning Collections Action(s) Under             
          Section 6320 and/or 6330 with regard to their unpaid taxes for              
          1996 and 1997.1  On August 8, 2001, respondent issued to                    
          petitioner Paul L. Hickey a Notice of Determination Concerning              
          Collection Action(s) Under Section 6320 and/or 6330 with regard             
          to his unpaid tax for 1998.                                                 
               On August 9, 2001, petitioners filed a Complaint with the              
          U.S. District Court for the District of Nevada (District Court)             
          challenging the notices of determination dated July 13, 2001.  On           
          September 10, 2001, petitioners filed an Amendment To Original              
          Complaint with the District Court seeking to amend their                    
          complaint to challenge the notice of determination dated August             
          8, 2001.                                                                    
               On September 12, 2001, the Government filed a motion to                
          dismiss the District Court action.  On February 15, 2002, the               
          District Court entered a Judgment on its Order dismissing                   
          petitioners’ Complaint for lack of subject matter jurisdiction.             
          The District Court observed in its Order that petitioners would             
          have “thirty days in which to bring their claim in the Tax                  

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       

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