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motion for summary judgment and to impose a penalty under section
6673. We shall grant respondent’s motion for summary judgment.
Background
The record establishes or the parties do not dispute the
following.
In 2003, respondent sent petitioner notices of deficiency
with respect to petitioner’s taxable years 2000 and 2001.
Petitioner received the notices but did not petition the Tax
Court with respect to these notices.
Respondent assessed the deficiencies and sent petitioner
notices of tax due and demand letters. On August 4, 2004,
respondent issued petitioner a Notice of Federal Tax Lien Filing
and Your Right to a Hearing under section 6320. On September 7,
2004, respondent received petitioner’s Form 12153, Request for a
Collection Due Process Hearing. In this request, petitioner
stated that he “would need to see” certain documents “before I am
persuaded that I am legally obligated to pay the taxes at issue”.
The documents requested included a summary record of assessment,
a copy of the notice and demand for payment, and the “pocket
commission” of the IRS employee who signed the notice of lien.
1(...continued)
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code of 1986, as amended.
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Last modified: May 25, 2011