T.C. Memo. 2008-33 UNITED STATES TAX COURT PAUL J. KENNEDY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10139-07L. Filed February 19, 2008. Paul J. Kennedy, pro se. Gordon P. Sanz, for respondent. MEMORANDUM OPINION GOEKE, Judge: This collection review case is before the Court on respondent’s motion to dismiss for lack of jurisdiction. Respondent submits that there is no notice of determination which this Court has jurisdiction to review. Petitioner, however, argues that no valid notice of Federal tax lien (NFTL) filing nor final notice of intent to levy and notice of the right to aPage: 1 2 3 4 5 6 7 8 NextLast modified: March 27, 2008