Leonard Parker v. Commissioner

117 T.C. No. 6

UNITED STATES TAX COURT LEONARD PARKER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2712-00L. Filed August 21, 2001. Before the effective date of secs. 6320 and 6330, I.R.C. (the effective date), R filed Federal income tax liens against certain property owned by P. After the effective date, R notified P under sec. 6331, I.R.C., that R intended to levy upon the property and offered to P the administrative hearing required by sec. 6330, I.R.C. R later issued to P a notice of determination as to the proposed levy, and P petitioned the Court to review that…