OPINION
HOLMES, Judge:
A taxpayer who gets a notice telling him that the IRS is about to levy on his property has 30 days to ask for a collection due process (CDP) hearing. If his request is late, we know what happens—he gets no CDP hearing. But what if his request is early?
This is the novel question raised by this motion to dismiss.
Background
On September 28, 2001, the Commissioner sent Anthony and...
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