Weber v. Comm'r
United States Tax Court
On Dec. 19, 2002, R mailed to P two notices of determination concerning collection action. R issued the first notice with respect to P's liability for unpaid income taxes; R issued the second notice with respect to P's liability for an unpaid civil penalty under sec. 6682, I.R.C. R sent both notices to P by certified mail addressed to him at his last known address. The first notice was returned to R by the U.S.
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On Dec. 19, 2002, R mailed to P two notices of determination concerning collection action. R issued the first notice with respect to P's liability for unpaid income taxes; R issued the second notice with respect to P's liability for an unpaid civil penalty under sec. 6682, I.R.C. R sent both notices to P by certified mail addressed to him at his last known address. The first notice was returned to R by the U.S. Postal Service marked "unclaimed". By letter dated Aug. 4, 2003, R's settlement officer sent P courtesy copies of the notices of determination. On Sept. 4, 2003, P filed a petition for…
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(4), and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Armen, Special Trial Judge:
This collection review case is before the Court on respondent’s motion to dismiss for lack of jurisdiction. Respondent contends that the Court lacks jurisdiction on the ground the petition for lien or levy action was not timely filed. As discussed in detail below, we…
2Cases cited20 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Davis v. CommissionerUnited States Tax Court · 2000
- Frieling v. CommissionerUnited States Tax Court · 1983
- Offiler v. CommissionerUnited States Tax Court · 2000
- William L. King and Darlene E. King v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
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3Cited by26 opinions
- Orum v. Comm'rUnited States Tax Court · 2004
- Mason v. Comm'rUnited States Tax Court · 2009
- Kasper v. CommissionerUnited States Tax Court · 2011
- Boyd v. Comm'rUnited States Tax Court · 2005
- Myers v. Comm'r of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2019
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