Greenoak Holdings Limited, Southbrook Properties Limited and Westlyn Properties Limited v. Commissioner

Ruwe, Judge:

Respondent issued a notice of determination to the personal representative of the Estate of James B. Irwin on May 1, 2013. Greenoak Holdings Limited, Southbrook Properties Limited, and Westlyn Properties Limited (petitioners) filed a petition for judicial review with the Tax Court on May 30, 2013. The issues for decision are: (1) whether petitioners’ alleged ownership interest in property that might be subject to levy by respondent entitles them to the rights afforded to “persons” under section 6330 1 and (2) whether this Court has jurisdiction under section 6330(d) of an appeal…