Meyer v. Comm'r
United States Tax Court
R issued final notices of intent to levy to Ps. The notices requested payment of frivolous return penalties imposed under sec. 6702, I.R.C., for the taxable years 1996 and 1997. Ps requested an Appeals Office hearing pursuant to sec. 6330(b), I.R.C. On Jan. 13, 2000, prior to conducting an Appeals Office hearing, R issued determination letters to Ps stating that R would proceed with collection.
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R issued final notices of intent to levy to Ps. The notices requested payment of frivolous return penalties imposed under sec. 6702, I.R.C., for the taxable years 1996 and 1997. Ps requested an Appeals Office hearing pursuant to sec. 6330(b), I.R.C. On Jan. 13, 2000, prior to conducting an Appeals Office hearing, R issued determination letters to Ps stating that R would proceed with collection. On Feb. 23, 2000, the Court received and filed petitions for review of R's determination letters that Ps had mailed to the Court on Feb. 15, 2000. R filed motions to dismiss the petitions for lack of…
1Opinion of the Court
OPINION
Dawson, Judge:
These cases were assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4).2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Panuthos, Chief Special Trial Judge:
These cases are before the Court on respondent’s motions to dismiss for lack of jurisdiction, as supplemented. As discussed in detail below, we will dismiss these cases for lack of jurisdiction on the ground that respondent’s notices of determination concerning collection action are…
2Cases cited13 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Naftel v. CommissionerUnited States Tax Court · 1985
- Davis v. CommissionerUnited States Tax Court · 2000
- Katz v. CommissionerUnited States Tax Court · 2000
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3Cited by25 opinions
- Lunsford v. Comm'rUnited States Tax Court · 2001
- MOORHOUS v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- KENNEDY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Johnson v. Comm'rUnited States Tax Court · 2001
- Thompson v. CommissionerUnited States Tax Court · 2011
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