PARKER v. COMMISSIONER

Docket No. 2712-00L.

117 T.C. 63 (2001)

117 T.C. No. 6

LEONARD PARKER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 21, 2001.


Attorney(s) appearing for the Case

Robert E. Kovacevich, for petitioner.

Catherine L. Campbell, for respondent.


OPINION

LARO, Judge:

Petitioner petitioned the Court to review respondent's determination as to a proposed levy upon petitioner's property. See sec. 6330(d).1 Respondent now moves the Court to dismiss the case for lack of jurisdiction, asserting that respondent filed the Federal tax liens against the property subject to the proposed levy before the effective date of sections 6320 and 6330. Because respondent notified petitioner...

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