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About This Document: In the Maureen Patricia Wilson v. Commr. case, the Petitioner (P) did not timely request a hearing with the IRS's (R) Appeals Office with respect to a proposed levy action. As a result, that office held an equivalent hearing with respect to that proposed action. Thereafter, R's Appeals Office sent P a document entitled "NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) under Section 6320 and/or 6330 in which that office recited those facts. In the document that R's Appeals Office sent P, that office concluded that it was sustaining the proposed levy action and that P was not entitled to seek judicial review of the conclusions in that document. Inconsistently, R's Appeals Office concluded in the document that it sent P that P was entitled to seek judicial review of the conclusions therein by timely filing a petition with the Court. The Tax Court held, the document that R's Appeals Office sent P does not embody a determination under Section 6330. The Tax Court further held that the document is not a valid notice of determination under Section 6330 that P is entitled to appeal under Section 6330(d)(1). The Court further held the Court does not have jurisdiction over this case.

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Categories: DocStore > Periodicals > Business & Economics
Tags: United States. Tax Court. Reports, Sep 1-Oct 31, 2008, MAUREEN PATRICIA WILSON, PETITIONER v. COMMISSIONER OF INTERNA..., RESPONDENT, Anonymous, News, Tax court decisions -- 131 TC 47, Appeals, Judicial reviews, Internal Revenue Code -- Section 6330, United States--US

MAUREEN PATRICIA WILSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

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MAUREEN P

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