Tax Court: Collection Due Process “Disregard” Letter is Sufficient for Jurisdiction

The Tax Court, in a reviewed opinion authored by the indefatigable Judge Dawson, holds that a decision letter from the Office of Appeals disregarding the frivolous arguments of a taxpayer, along with other legitimate arguments, is a determination under Section 6330(d)(1) for jurisdictional purposes.

Read the opinion here:
Thornberry v. Commissioner, 136 T.C. No. 16 (2011)