Wilson v. Comm'r
United States Tax Court
P did not timely request a hearing with R's Appeals Office with respect to a proposed levy action. As a result, that office held an equivalent hearing with respect to that proposed action. Thereafter, R's Appeals Office sent P a document entitled "NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330" in which that office recited those facts.
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P did not timely request a hearing with R's Appeals Office with respect to a proposed levy action. As a result, that office held an equivalent hearing with respect to that proposed action. Thereafter, R's Appeals Office sent P a document entitled "NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330" in which that office recited those facts. In the document that R's Appeals Office sent P, that office concluded that it was sustaining the proposed levy action and that P was not entitled to seek judicial review of the conclusions in that document.…
1Opinion of the Court
OPINION
CfflECHl, Judge:
This case is before the Court on its Order dated May 30, 2008 (Court’s Show Cause Order), in which the Court ordered each party to file a written response to that Order showing why this case should not be dismissed for lack of jurisdiction. We shall make the Court’s Show Cause Order absolute and dismiss this case for lack of jurisdiction.
The record establishes and/or the parties do not dispute the following.
Petitioner’s address shown in the petition in this case was in Belleville, Michigan.
On June 29, 1998, respondent assessed against petitioner a trust fund recovery…
2Cases cited5 opinions
- Craig v. Comm'rUnited States Tax Court · 2002
- Offiler v. CommissionerUnited States Tax Court · 2000
- Lunsford v. Comm'rUnited States Tax Court · 2001
- MOORHOUS v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- KENNEDY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
3Cited by14 opinions
- Cooper v. Comm'rUnited States Tax Court · 2010
- SECC Corp. v. CommissionerUnited States Tax Court · 2014
- American Airlines, Inc. v. CommissionerUnited States Tax Court · 2015
- Burt Kroner v. CommissionerUnited States Tax Court · 2020
- Cooper v. Comm'rUnited States Tax Court · 2010
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