United States Tax Court
Lucielle J. Offiler, A.k.a. Lucille Offiler v. Commissioner of Internal Revenue
June 19, 2000114 T.C. 492
Summary
The Court dismissed the petition for lack of jurisdiction because the taxpayer did not timely request a collection due process hearing after receiving the levy notice, so Appeals never issued the determination required for judicial review. A later request under the IRS's discretionary collection appeal program did not create the statutory determination needed for Tax Court jurisdiction.