- 2 - notice of determination for 1999 which concluded that the proposed collection activities would be sustained. Ps filed a petition to dispute the decision letter and the notice of determination. R filed a motion to dismiss for lack of jurisdiction with respect to 1998. 1. Held: The June 23, 2000, notice of intent to levy was sent to the last known address of Ps. 2. Held, further, R’s motion to dismiss for lack of jurisdiction is granted. Ps did not file a sec. 6330, I.R.C., hearing request within 30 days of the June 23, 2000, notice of intent to levy. See sec. 6330(a)(3), I.R.C. The Dec. 14, 2001, notice of intent to levy did not entitle petitioners to a sec. 6330, I.R.C., hearing. Sec. 301.6330-1(b)(2), Q&A-B2, Q&A- B4, Proced. & Admin. Regs. The decision letter subsequently issued does not provide a basis for the Court’s jurisdiction under sec. 6330(d)(1), I.R.C. See Moorhous v. Commissioner, 116 T.C. 263, 270 (2001); Kennedy v. Commissioner, 116 T.C. 255, 262 (2001). 3. Held, further, R did not abuse his discretion in issuing the notice of determination for 1999, and the proposed collection action is sustained. Keith Orum, pro se. Sean R. Gannon, for respondent. OPINION HAINES, Judge: Respondent sent petitioner Keith Orum (Mr. Orum) and petitioner Cherie Orum (Mrs. Orum) a Decision Letter Concerning Equivalent Hearing Under Section 6320 and/or 6330 (decision letter) for 1998 and a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) for 1999.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011