McCune v. Commissioner
United States Tax Court
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.
Read the full summary
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 adverse determination, his Tax Court petition is dismissed for lack of jurisdiction.
1Opinion of the Court
DAVID C. MCCUNE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
McCune v. Commissioner
No. 2837-00L
United States Tax Court
115 T.C. 114; 2000 U.S. Tax Ct. LEXIS 50; 115 T.C. No. 7;
August 8, 2000, Filed
An order will be entered granting respondent's Motion to Dismiss for Lack of Jurisdiction.
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
2Cases cited4 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- McCune v. CommissionerUnited States Tax Court · 2000
- Joannou v. CommissionerUnited States Tax Court · 1960
- Hodges v. CommissionerUnited States Tax Court · 1987