Guralnik v. Comm'r
United States Tax Court
R mailed P a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. On February 13, 2015, P sent his petition to this Court via Federal Express First Overnight service, which was not then a "designated delivery service" under I.R.C. sec. 7502(f)(2). P's petition was required to be filed "within 30 days of a determination under this section."
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R mailed P a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. On February 13, 2015, P sent his petition to this Court via Federal Express First Overnight service, which was not then a "designated delivery service" under I.R.C. sec. 7502(f)(2). P's petition was required to be filed "within 30 days of a determination under this section." I.R.C. sec. 6330(d)(1). On the last date for timely filing of the petition, Tuesday, February 17, 2015, all Federal Government offices in the District of Columbia, including the Tax Court, were officially closed on account…
1Opinion of the Court
FELIX GURALNIK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Guralnik v. Comm'r
Docket No. 4358-15L.
United States Tax Court
146 T.C. 230; 2016 U.S. Tax Ct. LEXIS 16; 146 T.C. No. 15;
June 2, 2016, Filed
An order will be issued denying respondent's motion to dismiss for lack of jurisdiction.
R mailed P a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. On February 13, 2015, P sent his petition to this Court via Federal Express First Overnight service, which was not then a "designated delivery service" under I.R.C. sec. 7502(f)(2). P's petition was…
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