- 5 - Decision Letters I and II both 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.” Petitioner filed a motion for partial summary judgment as to tax year 1995. Respondent filed an objection to petitioner’s motion for partial summary judgment as to tax year 1995. Respondent filed a motion to dismiss for lack of jurisdiction in both of these consolidated cases. Petitioners filed objections to respondent’s motions to dismiss. In docket No. 12212-04L, respondent filed first and second supplements to the motion to dismiss for lack of jurisdiction. In docket No. 12136-04L, respondent filed a supplement to the motion to dismiss for lack of jurisdiction. Petitioners filed a supplemental objection to each motion to dismiss. The Court held a hearing on petitioner’s motion for partial summary judgment and respondent’s motions to dismiss for lack of jurisdiction. OPINION The parties dispute whether petitioners are entitled to a collection hearing. Respondent argues that this Court should dismiss the case for lack of jurisdiction as petitioners did notPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011