Carol Diane Gray v. Commissioner

140 T.C. No. 9

UNITED STATES TAX COURT CAROL DIANE GRAY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 27849-09L. Filed April 25, 2013. P moved for interlocutory appeal pursuant to I.R.C. sec. 7482(a)(2)(A) of an order dismissing for lack of jurisdiction, on account of an untimely petition, that portion of the case seeking review under I.R.C. sec. 6330(d)(1) of R’s determination to proceed with collection actions. 1. Held: P’s contention that the period in which to file a petition for review of a collection action determination under I.R.C. sec. 6330 affecting the…