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Background
At the time he filed the petition in this case, petitioner
resided in Tijeras, New Mexico.
Respondent issued final notices of intent to levy with
respect to 1996 to 1999, inclusive, on February 23, 2003.
Respondent issued no notices of determination for 1996, 1997,
1998, 1999, and 2001. Respondent issued a final notice of intent
to levy for 2000 on the same date, and petitioner timely
requested an Internal Revenue Service (IRS) Appeals Office
hearing (hearing) under section 6330 for the year 2000 only.1
Respondent offered petitioner several options for the year 2000
1Sec. 6330(d)(1) was amended by the Pension Protection Act
of 2006, Pub. L. 109-280, sec. 855(a), 120 Stat. 1019, effective
for determinations made after the date which is 60 days after
Aug. 17, 2006, to provide, in effect, that the Tax Court shall
have jurisdiction for appeals from all determinations made under
sec. 6330. Before the amendment, and as applicable to this case,
sec. 6330(d)(1) provided:
SEC. 6330(d). Proceeding After Hearing.--
(1) Judicial review of determination.--The person
may, within 30 days of a determination under this
section, appeal such determination--
(A) to the Tax Court (and the Tax Court
shall have jurisdiction with respect to such
matter); or
(B) if the Tax Court does not have
jurisdiction of the underlying tax liability,
to a district court of the United States.
If a court determines that the appeal was to an
incorrect court, a person shall have 30 days after the
court determination to file such appeal with the
correct court.
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Last modified: May 25, 2011