FLORIDA COMMUNITY BANK, AS SUCCESSOR v. TIVOLI RESERVE, LLC

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that the Commissioner may not waive the time restrictions imposed in section 6330
• holding that the Court lacks jurisdiction to review a decision letter issued following an \equivalent hearing\ where the taxpayer failed to make a timely request for an administrative hearing
• noting that the Commissioner may not waive the time restrictions imposed by section 6330
• dismissing petition on jurisdictional grounds because the IRS failed to mail the required notice to taxpayer before filing a lien

Source: CourtListener parenthetical corpus (CC0).