§63301

Walker, seek review pursuant to section 63301 of a determination by the Internal Revenue Service (IRS) Independent Office of Appeals (Appeals) upholding a proposed levy collection action for tax year 2018 and denying their request for abatement of additions to tax and their challenge to the underlying tax liability.

Epps, seeks review pursuant to section 63301 of a determination by the Internal Revenue Service (IRS) Independent Office of Appeals (Appeals Office) upholding a notice of intent to levy (levy notice).

Nelson, seeks review pursuant to section 63301 of a determination by the Internal Revenue Service (IRS) Independent Office of Appeals (Office of Appeals) upholding a notice of intent to levy (levy notice) with respect to his 2015–19 tax years.

MEMORANDUM OPINION URDA, Judge: In this collection due process (CDP) case petitioner, Douglas James Casement, seeks review pursuant to section 63301 of a determination by the Internal Revenue Service (IRS) Independent Office of Appeals upholding a notice of intent to levy with respect to unpaid federal income tax liabilities for his 2010, 2011, and 2012 taxable years.2 The Commissioner has moved for summary 1 Unless otherwise indicated, statuto

Cloar, seeks review pursuant to section 63301 of a determination by the Internal Revenue Service (IRS) Independent Office of Appeals2 (Appeals) upholding a proposed levy collection action for tax years 2008, 2009, 2010, and 2012 (years at issue) and rejecting Mr.

MEMORANDUM OPINION URDA, Judge: In this collection due process (CDP) case petitioner, David James Dick, Jr., seeks review pursuant to section 63301 of a determination by the Internal Revenue Service (IRS) Independent Office of Appeals (Appeals Office) upholding a notice of intent to levy (Notice) with respect to unpaid federal income tax liabilities for his 2011–16 and 2018 taxable years.

On June 15, 2007, respondent filed a motion to di miss for lack of jurisdiction on the grounds that no notice of etermination unde r SERVED MAR 2 5 2008 2 - section 6320 or section 63301 was sent to petitioner for the tax years 1993, 1994, and 1995 that would confer jurisdiction on this Court .

Salazar's employment tax liabilities for the quarters ended December 1998 through June 2001 on the grounds that (1) respondent never issued a notice of determination - 2 - concerning a collection action under section 63301 with respec t to the employment tax liabilities, and (2) the Tax Court does not have jurisdiction over Mr.

MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Judge: Respondent sent petitioner a Notice Of Determination Concerning Collection Action(s) under Section 63301 (Levy), in which respondent determined to proceed with collection 1 Unless otherwise stated, section references are to the Internal Revenue Code.

Respondent contends that all section 63301 prerequisites have been met and that he should be allowed to proceed with collection.

On May 15, 2002, the Appeals officer sent petitioner a letter proposing a section 63301 hearing (hearing) on July 9, 2002.

After the cancellation of two previously scheduled section 63301 hearings, one was held with petitioner on February 22, 2002.

On October 17, 2001, Settlement Officer Salinger and petitioners participated in a section 63301 hearing.

MEMORANDUM OPINION FOLEY, Judge: The issues in this case are whether respondent has met the requirements of section 63301 and whether petitioners are liable for the section 6673(a)(1) penalty.