Gregory Meeker - Page 5

                                        - 5 -                                         
               At the hearing on respondent’s motion, petitioner stated:              
          “Basically, the only thing I have before the Court, and the only            
          thing that’s--as far as I’m concerned, is the default I have                
          against them [the Internal Revenue Service] for not answering my            
          First Amendment complaint.”  Petitioner further stated:  “What              
          I’m saying is they [the Internal Revenue Service] don’t have                
          jurisdiction to issue anything to me.  I’m not under their                  
          I.   Decision Letter                                                        
               A decision letter is not a determination letter pursuant to            
          section 6320 or 6330.  See Kennedy v. Commissioner, 116 T.C. 255,           
          263 (2001); Offiler v. Commissioner, 114 T.C. 492, 495 (2000).              
          Respondent did not issue a determination letter to petitioner               
          sufficient to invoke the Court’s jurisdiction to review the                 
          notice of intent to levy for 2001.  Kennedy v. Commissioner,                
          supra.  Insofar as the petition filed herein purports to be a               
          petition for review pursuant to section 6330(d) of the notice of            
          intent to levy for 2001, we shall dismiss the petition as to the            
          notice of intent to levy for 2001 for lack of jurisdiction on the           
          ground that respondent did not make a determination pursuant to             
          section 6330 regarding the notice of intent to levy for 2001                
          because petitioner failed to file a timely request for an Appeals           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011