Ranie M. Raymond - Page 3




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          and/or 6330 (notice of determination) regarding her 1991 tax                
          year.  In the notice of determination, respondent determined that           
          the collection against petitioner should be sustained because               
          petitioner did not file a joint return and, therefore, was not              
          entitled to raise a spousal defense.                                        
               On February 12, 2001, petitioner sent a letter to the Court            
          regarding the notice of determination.  The Court received the              
          letter on February 16, 2001.  The Court filed petitioner’s letter           
          as a Petition for Lien or Levy Action Under Code Section 6320(c)            
          or 6330(d) (petition).  On March 14, 2001, the Court received               
          petitioner’s amended petition, which was filed as an Amended                
          Petition for Lien or Levy Action Under Code Section 6320(c) or              
          6330(d).                                                                    
               On June 14, 2001, respondent filed a Motion to Dismiss for             
          Lack of Jurisdiction on the ground that the petition was not                
          filed within the time prescribed by section 6330(d).  Petitioner            
          objected to this motion.  On January 2, 2002, respondent filed a            
          Motion to Withdraw Respondent’s Motion to Dismiss for Lack of               
          Jurisdiction.  On January 2, 2002, respondent also filed a Motion           
          for Partial Summary Judgment on the issue of whether petitioner             
          is eligible for relief under section 6015.  On January 30, 2002,            
          petitioner filed a response to respondent’s motion for partial              
          summary judgment wherein petitioner objected to the granting of             
          the motion.                                                                 






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