David D. Smith - Page 1

                                   124 T.C. No. 3                                     


                               UNITED STATES TAX COURT                                


                            DAVID D. SMITH, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 11109-04L, 11110-04L. Filed February 8, 2005.              


                    On Aug. 26, 2003, R issued to P separate Final                    
               Notices of Intent to Levy and Notice of Your Right to a                
               Hearing with regard to his unpaid Federal income taxes                 
               for the taxable years 1985 to 1995 and for the taxable                 
               years 1996 to 1999.  P submitted to respondent timely                  
               requests for a hearing under sec. 6330, I.R.C.                         
                    On Mar. 3, 2004, P filed a bankruptcy petition                    
               under ch. 7 of the Bankruptcy Code.                                    
                    On May 25, 2004, while P’s bankruptcy case                        
               remained open, R issued to P separate Notices of                       
               Determination Concerning Collection Actions for the                    
               taxable years 1985 to 1995 and the taxable years 1996                  
               to 1999.  On June 28, 2004, P filed with the Court                     
               petitions for lien or levy action challenging R’s                      
               notices.  R filed motions to dismiss for lack of                       
               jurisdiction on the ground the petitions were filed in                 







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