Adolphson v. Commissioner

WILLIAMS, Circuit Judge.

This is a difficult tax case made more so by the refusal of the Commissioner of Internal Revenue -to engage the taxpayer’s arguments or the tax court’s decision. Kerry Adolphson, who has failed to file a tax return since at least 2002, challenges levies used by the IRS to collect his unpaid taxes. The tax court dismissed his petition for lack of subject-matter jurisdiction because Adolphson had not challenged the levies administratively, see 26 U.S.C. § 6330(d), and, therefore, lacked the requisite notice of determination from the IRS Office of Appeals.

Adolphson…