Gray v. Commissioner
United States Tax Court
R issued and mailed to P a notice of determination concerning collection actions under I.R.C. secs. 6320 and/or 6330, with respect to unpaid income taxes for 1992, 1993, 1994, and 1995, on Oct. 16, 2009. The notice determined that a proposed lien and levy should be sustained. Although P had requested relief under I.R.C. sec. 6015 for the years in issue at her hearing, the notice was silent with respect thereto.
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R issued and mailed to P a notice of determination concerning collection actions under I.R.C. secs. 6320 and/or 6330, with respect to unpaid income taxes for 1992, 1993, 1994, and 1995, on Oct. 16, 2009. The notice determined that a proposed lien and levy should be sustained. Although P had requested relief under I.R.C. sec. 6015 for the years in issue at her hearing, the notice was silent with respect thereto. Petitioner had previously requested I.R.C. sec. 6015 relief for the same years and received a final determination with respect thereto in 2000, for which she did not file a petition…
1Opinion of the Court
OPINION
Gale, Judge:
The petition in this case seeks review of a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 2 issued by respondent’s Office of Appeals (Appeals). In the notice of determination Appeals determined both to sustain the proposed collection actions (a lien and a levy) and to reject petitioner’s request for an abatement of interest. The notice of determination was mailed on October 16, 2009. The envelope containing the petition bears a U.S. Postal Service (USPS) postmark of November 17, 2009. The petition was received by the Court and filed…
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