Gray v. Community of Internal Revenue

Tax Court did not err in dismissing as untimely plaintiff’s petitions for review of IRS “notices of determination” that approved imposition of liens and levies to collect on plaintiff’s delinquent taxes. Under 26 USC section 6330(d)(1), relevant deadline for filing instant petitions was 30 days after IRS sent said notices to plaintiff, and record showed that plaintiff had filed instant petitions beyond said deadline. Ct. rejected plaintiff’s claim that 90-day deadline (for seeking review of IRS assessments) under 26 USC section 6213(a) applied to her petitions, since IRS did not challenge amounts that plaintiff reported on her tax returns.