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The Decision Letter stated in part: “Your due process
hearing request was not filed within the time prescribed under
Section 6320 and/or 6330. However, you received a hearing
equivalent to a due process hearing except that there is no right
to dispute a decision by the Appeals Office in court under IRC
Sections 6320 and/or 6330.”
Respondent filed a motion to dismiss for lack of
jurisdiction. Petitioner filed an objection to respondent’s
motion to dismiss. Respondent filed a supplement to the motion
to dismiss for lack of jurisdiction. Petitioner filed a
supplemental objection to the motion to dismiss.
The Court held a hearing on respondent’s motion to dismiss
for lack of jurisdiction.
OPINION
The parties dispute whether petitioner is entitled to a
collection hearing. Respondent argues that this Court should
dismiss the case for lack of jurisdiction as petitioner did not
file a timely hearing request in response to each first Notice of
Federal Tax Lien filed for tax years 1995, 1996, and 1997.
Petitioner argues that he did not receive the March 1, 2000, or
the March 19, 2001, notice, that the first notice regarding his
1995, 1996, and 1997 liabilities that he received was in November
2003, and he requested a hearing in response to that notice.
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Last modified: May 25, 2011