Parker v. Comm'r
United States Tax Court
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 determination.
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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 determination. R asserts that the Court lacks jurisdiction to review the determination because it involves property against which R filed a lien before the…
1Opinion of the Court
OPINION
Laro, Judge:
Petitioner petitioned the Court to review respondent’s determination as to a proposed levy upon petitioner’s property. See sec. 6330(d).1 Respondent now moves the Court to dismiss the case for lack of jurisdiction, asserting that respondent filed the Federal tax liens against the property subject to the proposed levy before the effective date of sections 6320 and 6330. Because respondent notified petitioner after that effective date of respondent’s intent to levy upon petitioner’s property, we shall deny respondent’s motion.
Background
The facts set forth in this section are…
2Cases cited1 opinion
- Metrocorp, Inc. v. CommissionerUnited States Tax Court · 2001
3Cited by8 opinions
- Meehan v. Comm'rUnited States Tax Court · 2004
- Stein v. Comm'rUnited States Tax Court · 2004
- Gilliam v. Comm'rUnited States Tax Court · 2010
- Leonard Parker v. CommissionerUnited States Tax Court · 2001
- Marty J. Meehan v. CommissionerUnited States Tax Court · 2004
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