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.
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