Dorn v. Comm'r
United States Tax Court
To collect petitioner's (P) unpaid income tax liabilities for 1987-89, respondent (R) issued a notice of levy to a fund in which petitioner maintained accounts and issued to P a notice of jeopardy levy and right to appeal. See sec. 6330(f), I.R.C. P requested and R held a hearing under sec. 6330(b), I.R.C. After the hearing, R determined that imposition of a jeopardy levy was appropriate.
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To collect petitioner's (P) unpaid income tax liabilities for 1987-89, respondent (R) issued a notice of levy to a fund in which petitioner maintained accounts and issued to P a notice of jeopardy levy and right to appeal. See sec. 6330(f), I.R.C. P requested and R held a hearing under sec. 6330(b), I.R.C. After the hearing, R determined that imposition of a jeopardy levy was appropriate. P filed a petition under sec. 6330(d), I.R.C., seeking judicial review of that determination. Held: The Tax Court has jurisdiction under sec. 6330(d), I.R.C., to review R's determination that R's use of a…
1Opinion of the Court
Colvin, Judge:
Petitioner filed the petition in this case under section 6330(d) seeking our review of respondent’s determination that use of a jeopardy levy was appropriate. The sole issue for decision in this Opinion is whether the Tax Court has jurisdiction to review respondent’s determination that a jeopardy levy was appropriate. We hold that we do.
Section references are to the Internal Revenue Code as amended.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner resided in Naples, Florida, when he filed his petition.
Petitioner maintained various accounts in a…
2Cases cited8 opinions
- Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000
- Naftel v. CommissionerUnited States Tax Court · 1985
- Woodral v. CommissionerUnited States Tax Court · 1999
- Federal Trade Commission v. Mandel Bros.Supreme Court of the United States · 1959
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
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