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Allen E. Jones, for petitioners.
A. Gary Begun, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: This case is before the Court on
respondent’s motion to dismiss for lack of jurisdiction (the
motion). Petitioners object. Respondent’s grounds are that the
petition was not filed within the time prescribed by section
6330(d)(1)(A). An evidentiary hearing was held in Detroit,
Michigan, on June 10, 2002, at which testimony was taken and
other evidence was received. On the basis of the evidence, and
for the reasons that follow, we shall grant the motion.
Unless otherwise indicated, all section references are to
the Internal Revenue Code presently in effect, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
At the time the petition was filed, petitioners, husband and
wife, resided in Deckerville, Michigan.
On December 18, 2001, the Internal Revenue Service Appeals
Office in Detroit, Michigan, mailed to each petitioner a “Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330", which notices (the notices) are identical
except for name and salutation. The notices concern petitioners’
unpaid joint Federal income tax liabilities for 1995 and 1996.
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