David Broomfield - Page 2

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          6330(d)(1).1  Petitioner filed an objection to respondent's                 
          motion.  The parties then filed seriatim responses to                       
          petitioner's objection.  A hearing was held on respondent's                 
          motion.  Petitioner, who is incarcerated, did not appear but                
          instead submitted a statement under Rule 50(c).  Respondent                 
          offered the testimony of the settlement officer who handled                 
          petitioner's request for a hearing under section 6330.  We base             
          our findings on the facts that are not in dispute, petitioner's             
          submissions, and various documents from petitioner's                        
          administrative file in the record.  We rely on respondent's                 
          witness's testimony only to the extent it contains admissions or            
          establishes the foundation for admitting the material in                    
          petitioner's administrative file.                                           
                                     Background                                       
               Petitioner was incarcerated at Oakhill Correctional                    
          Institution in Oregon, Wisconsin, at the time the petition was              
          filed.                                                                      
               On April 30, 2002, a Final Notice - Notice of Intent to Levy           
          and Notice of Your Right to a Hearing, was mailed to petitioner             
          at 3401 West Wanda Avenue, Milwaukee, Wisconsin ("Wanda Avenue              
          address"), regarding unpaid Federal income taxes for 1991.  On              

               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  





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