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