David C. McCune v. Commissioner

115 T.C. No. 7

UNITED STATES TAX COURT DAVID C. MCCUNE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2837-00L. Filed August 8, 2000. More than 30 days after receiving an adverse Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, P sought judicial review in a Federal District Court. The petition was dismissed for lack of subject matter jurisdiction. More than 30 days after the order of dismissal, P sought review in this Court. Held: Because P failed to file his initial petition with the District Court within 30 days of the notice of…