Kenneth N. Headley - Page 3

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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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