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hearing (notice of intent to levy) was sent to his proper
address. Because we find that respondent has not issued a valid
NFTL or a valid notice of intent to levy, we shall dismiss this
case for lack of jurisdiction.
Background
At the time this petition was filed, petitioner resided at
1101 Kost Road in Alvin, Texas (the Kost Road address). It
appears that petitioner has not filed income tax returns since
1996. According to respondent, petitioner’s last known address
was RR 4, Box 415, Alvin, Texas 77511 (the Box 415 address).
While petitioner did in fact reside at this address at some
point, the parties agree that petitioner has not lived there for
some time.
On July 9, 2001, respondent’s Collection Branch sent a
Letter 2797 addressed to petitioner at the Kost Road address.
The Letter 2797 asked petitioner to verify that the Kost Road
address was his correct address. Petitioner checked the box
indicating that the Kost Road address was in fact his correct
address. Petitioner then mailed the completed Letter 2797 back
to respondent by certified mail. According to the return
receipt, respondent received the completed Letter 2797 on July
19, 2001, in Ogden, Utah.
On or about February 16, 2007, respondent issued the NFTL
with respect to petitioner’s tax liabilities for the years 1999,
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