T.C. Memo. 2007-138
UNITED STATES TAX COURT
FRED SEBASTIAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8013-05L. Filed May 31, 2007.
On Mar. 10, 2005, R sent a notice of determination
concerning collection action by certified mail to P’s
last known address. The address contained an erroneous
ZIP Code. Delivery attempts were made on Mar. 14 and
Apr. 11, 2005. The notice of determination was
delivered on Apr. 13, 2005.
P filed a petition on Apr. 27, 2005. R filed a
motion to dismiss P’s petition for lack of jurisdiction
on the ground that it was not filed timely.
Held: The notice of determination concerning
collection action is valid as it was sent by certified
mail to petitioner’s last known address.
Held, further: Because P did not file timely his
petition, this Court lacks jurisdiction to review R’s
determination to proceed with collection action.
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Last modified: November 10, 2007