Offshore Trustees Beware: No Pre-Levy Notice for You!

Phyllis C. Taite, Florida A&M University College of Law


In Greenoak Holdings Ltd. v. Commissioner, the Tax Court addressed whether a third party with an ownership interest in property subject to levy by the commissioner is entitled to rights afforded to “persons” under section 6330. The court also addressed whether it had jurisdiction over an appeal filed by those third parties, and it ultimately dismissed the case for lack of jurisdiction.