Legal Opinion

McCune v. Commissioner

United States Tax Court

Decided August 8, 2000No. 2837-00LPublished

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.

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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

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. McCune v. CommissionerUnited States Tax Court · 2000
  3. Joannou v. CommissionerUnited States Tax Court · 1960
  4. Hodges v. CommissionerUnited States Tax Court · 1987

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