David Buffano - Page 1

                                 T.C. Memo. 2007-32                                   

                               UNITED STATES TAX COURT                                

                            DAVID BUFFANO, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11281-06L.           Filed February 8, 2007.                

                    R filed a motion to dismiss P’s collection review                 
               action directed at R’s effort to levy upon P’s                         
               property.  R argued lack of jurisdiction due to P’s                    
               untimely request for an Appeals Office hearing.  P                     
               argued that he did not timely receive notice of R’s                    
               intent to levy.                                                        
                    1.  Held:  R’s motion to dismiss for lack of                      
               jurisdiction on the ground that P made an untimely                     
               hearing request will be denied.                                        
                    2.  Held, further:  No valid final notice of                      
               intent to levy was issued because the notice was not                   
               mailed to P’s last known address.                                      
                    3.  Held, further:  This case will be dismissed                   
               for lack of jurisdiction because no valid final notice                 
               of intent to levy was issued to P.                                     

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