Kenneth N. Headley - Page 1

                                  T.C. Memo. 2007-7                                   

                               UNITED STATES TAX COURT                                

                         KENNETH N. HEADLEY, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 24891-04L.            Filed January 10, 2007.               

                    The Internal Revenue Service (IRS) issued final                   
               notices of intent to levy for a number of taxable                      
               years, but P requested an IRS Appeals Office hearing                   
               (hearing) under sec. 6330, I.R.C., for only one of                     
               these years--2000.  Upon P’s failure to participate in                 
               the granted hearing, an IRS Appeals officer made a                     
               determination as provided for in sec. 6330, I.R.C.,                    
               that the IRS could proceed with collection of P’s year                 
               2000 income tax liability.  In due course, R issued a                  
               Notice of Determination Concerning Collection Action(s)                
               Under Section 6320 and/or 6330 regarding that action.                  
                    P filed a complaint appealing the determination                   
               with the U.S. District Court.  The District Court                      
               dismissed the complaint sua sponte after P failed to                   
               serve the defendant (the United States).  P then filed                 
               a petition with the Tax Court within 30 days of the                    
               District Court’s dismissal of the Complaint, claiming                  
               that the District Court’s dismissal constituted a                      
               determination by the District Court that the appeal was                

Page:   1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011