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ADVERTISEMENT ADVERTISEMENT IRS Properly Notified Calif. Attorney Of Levy, Tax Court Says Law360 (January 14, 2021, 5:16 PM EST) A California attorney cannot challenge an Internal Revenue Service levy and seizure of his property, the U.S. Tax Court said Thursday in finding the agency complied with statutory notice requirements despite claims the original notice was never received. Wiley Ramey failed to receive the notice from the IRS until just before the 30-day window to request a hearing on his tax debt expired, but U.S. Tax Court Judge Emin Toro said the deadline to appeal his tax debt could not be extended. The agency s sending the notice to Ramey s last known address by certified mail started the clock on his right to. ....