- 9 -
petition this Court for the same reason we elaborated on for the
2000 tax year. The decision letters were dated October 23, 2003,
the petition was mailed on December 16, 2004, and subsequently
filed on December 27, 2004, and the additional 30-day filing
period is not appropriate. We will grant respondent’s motion to
dismiss for 1997 and 1998.
1996 Tax Year
Petitioner also includes the 1996 tax year in his petition,
challenging lien/levy determinations. Petitioner has offered
only a March 31, 2005, decision letter, not a notice of
determination. Accordingly, we will grant respondent’s motion to
dismiss for the 1996 tax year.
To reflect the foregoing,
An appropriate order and order of
dismissal will be entered granting
respondent’s motion to dismiss for
lack of jurisdiction.
Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011