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 inPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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