Inv. Research Assocs. v. Comm'r
United States Tax Court
R filed a Federal tax lien in Florida (Florida lien) and mailed to P a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 (lien notice) regarding P's unpaid taxes for 1980, 1982, 1984, 1985, 1986, 1987, 1988, 1989, and 1997 (the years in dispute). P did not submit to R a request for an administrative hearing with regard to the Florida lien.
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R filed a Federal tax lien in Florida (Florida lien) and mailed to P a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 (lien notice) regarding P's unpaid taxes for 1980, 1982, 1984, 1985, 1986, 1987, 1988, 1989, and 1997 (the years in dispute). P did not submit to R a request for an administrative hearing with regard to the Florida lien. Three months later, R filed a Federal tax lien in Illinois (Illinois lien) and mailed to P a second lien notice for the years in dispute. P submitted to R's Office of Appeals a request for an administrative hearing regarding the…
1Opinion of the Court
OPINION
Haines, Judge:
The question presented in this collection review case is whether the Court has jurisdiction under sections 6320 and 6330 to review the Decision Letter Concerning Equivalent Hearing (decision letter) upon which the petition for lien or levy action is based.1 As discussed in detail below, we conclude that petitioner failed to timely request an administrative hearing, and, therefore, the decision letter in dispute does not constitute a notice of determination which would permit petitioner to invoke this Court’s jurisdiction under sections 6320 and 6330. Consequently, we are…
2Cases cited14 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- United States v. CartwrightSupreme Court of the United States · 1973
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
9 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Gray v. CommissionerCourt of Appeals for the Seventh Circuit · 2013
- Newsome v. Comm'rUnited States Tax Court · 2007
- Mays v. Comm'rUnited States Tax Court · 2006
- Atlantic Pacific Management Group LLC v. CommissionerUnited States Tax Court · 2019
- Daniel v. Comm'rUnited States Tax Court · 2009
5 more not listed; retrieve them via the Exa API.