-2-
determination was issued to petitioner for the years at issue.
Petitioner contends that no final notice of intent to levy was
sent to him, and therefore respondent’s levy is improper.
Background
At the time the petition was filed, petitioner resided in
California.
On March 13, 2006, respondent sent petitioner by certified
mail a Final Notice-Notice of Intent to Levy and Notice of Your
Right to a Hearing for the years 2000 through 2003. The notice
of intent to levy was returned to respondent marked
refused/unclaimed on April 17, 2006. On February 2, 2007,
respondent sent petitioner by regular mail a Warning of Intent to
Levy. On May 8, 2007, respondent levied upon petitioner’s
accounts.
On June 25, 2007, petitioner submitted his petition, and the
Court filed his motion to restrain collection. Respondent
objected to petitioner’s motion on the ground that the Court
lacked jurisdiction. On August 13, 2007, the Court filed
respondent’s motion to dismiss for lack of jurisdiction. A
hearing on the motions was held on October 15, 2007, in San
Francisco, California.
1(...continued)
Internal Revenue Code as amended. Rule references are to the Tax
Court Rules of Practice and Procedure. Amounts are rounded to
the nearest dollar.
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Last modified: March 27, 2008