- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011