KENNEDY v. COMMISSIONER OF INTERNAL REVENUE
United States Tax Court
On Sept. 10, 1999, R mailed to P a notice required by sec. 6320(a), I.R.C., concerning P's unpaid tax liabilities for the years 1984 through 1988. R concedes that such notice was not mailed to P at his last known address.
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On Sept. 10, 1999, R mailed to P a notice required by sec. 6320(a), I.R.C., concerning P's unpaid tax liabilities for the years 1984 through 1988. R concedes that such notice was not mailed to P at his last known address. On Oct. 25, 1999, R mailed to P a final notice of intent to levy concerning P's unpaid tax liabilities for the years 1984 through 1988. Although the notice of intent to levy was mailed to P at his last known address, P failed to file a request for an administrative hearing with the Internal Revenue Service Office of Appeals (Appeals Office) within the 30-day period…
1Opinion of the Court
OPINION
Ruwe, Judge:
This case was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Armen, Special Trial Judge:
This matter is before the Court on respondent’s motion to dismiss for lack of jurisdiction. Respondent contends that the Court lacks jurisdiction over the petition on the ground that respondent did not issue a determination letter to petitioner pursuant to section 6320 or…
2Cases cited6 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Davis v. CommissionerUnited States Tax Court · 2000
- Offiler v. CommissionerUnited States Tax Court · 2000
- Abeles v. CommissionerUnited States Tax Court · 1988
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3Cited by63 opinions
- Orum v. Comm'rUnited States Tax Court · 2004
- MOORHOUS v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Behling v. Comm'rUnited States Tax Court · 2002
- Smith v. Comm'rUnited States Tax Court · 2005
- Lisa Edwards v. Commissioner of IRSCourt of Appeals for the D.C. Circuit · 2015
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