On January 14, 2021, the Tax Court issued its opinion in Ramey v. Commissioner (156 T.C. No. 1). The underlying issue presented in Ramey v. Commissioner was whether notice sent to last known address, shared by multiple businesses, and not left with anyone authorized to receive the petitioner’s mail, started the CDP Appeal clock in IRC § 6330(a)(2) and (3). Legal Background to Ramey v. Commissioner The IRS may not make a levy unless the IRS notifies the taxpayer in writing of the right to a hearing before the levy is made. IRC § 6330(a); IRC § 6330(b). The IRS must provide the required notice not less than 30 days before the day of the first levy. IRC § 6330(a)(2). The Code enumerates three acceptable ways of providing the notice. The notice may be (A) given in person; (B) left at the dwelling or usual place of business of such…