T.C. Memo. 2003-29 UNITED STATES TAX COURT MARY LOU AND ALLEN E. JONES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3965-02L. Filed February 6, 2003. On Dec. 18, 2001, R mailed to Ps separate, identical Notices of Determination Concerning Collection Action(s) Under Sec. 6320 and/or 6330, I.R.C. In addition to the Dec. 18, 2001, date stamped next to the word “Date”, each notice was stamped “FEB 16 2002", in the immediate proximity of the words “in re: Due Process Appeal (Tax Court)”. More than 30 days after the Dec. 18, 2001, mailing date of the notices, Ps filed a petition with the Tax Court seeking judicial review of the determination. R moved to dismiss the petition for lack of jurisdiction on the ground that the petition was not filed within the 30- day period prescribed in sec. 6330(d)(1)(A), I.R.C. Held: Because Ps failed to file their petition within 30 days of the notices of adverse determination, the petition is dismissed for lack of jurisdiction.Page: 1 2 3 4 5 6 7 8 Next
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