- 6 -
36 (1993); Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985).
When a motion for summary judgment is made, the nonmoving party
cannot rely upon the allegations or denials in its pleading but
must demonstrate with specific facts that there is a genuine
issue for trial. King v. Commissioner, 87 T.C. 1213, 1217
(1986); Shepherd v. Commissioner, T.C. Memo. 1997-555.
In his petition to this Court, petitioner raises no
discernable issues, except to argue generally that he disagreed
with the determination of the Appeals officer and that the
determination was not complete and was erroneous. The petition
states:
1. Petitioner disagrees with the determination under
��6230 and/or 6330 alleged for the year: 1990, 1991,
1992, 1993, and 1994 as set forth in the NOTICE OF
DETERMINATION CONCERNING COLLECTION ACTION(S) which is
dated FEB. 14, 2001, * * * and NOTICE OF FEDERAL TAX
LIEN * * *
2. Petitioner taxpayer identification number is: * * *
3. Petitioner disputes the following:
AMOUNT OF ADDITIONS TO TAX/
DEFICIENCY PENALTIES-I.R.C.
[interest disputed &
Years (disputed) penalties disputed]
1990 $1403.16 $Unknown
1991 $3241.50 $Unknown
1992 $427.57 $Unknown
1993 $1787.47 $Unknown
1994 $3379.82 $Unknown
4. Set forth those adjustments, i.e. changes, in the
FINAL NOTICE OF INTENT TO LEVY with which you disagree
and why you disagree: Respondent erred in its
administrative procedure against petitioner in issuing
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