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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