115 T.C. No. 26 UNITED STATES TAX COURT SCOTT WILLIAM KATZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16718-99L. Filed October 13, 2000. P received a notice of deficiency for his 1990 tax year. After P petitioned this Court to redetermine that deficiency determination, the Court entered a stipulated decision providing for a tax deficiency, additions to tax, and statutory interest. R subsequently filed a lien, and P, in turn, requested an Appeals hearing from R’s Appeals Office pursuant to sec. 6320(b), I.R.C. P refused to appear at the Appeals hearing on the grounds that the location of the Appeals hearing was inconvenient to P and his witnesses. After an Appeals officer discussed the collection matter with P via telephone, the Appeals officer issued to P a notice of determination under sec. 6330, I.R.C. P subsequently petitioned this Court to review the Appeals officer’s determination under sec. 6330, I.R.C. R now moves for partial summary judgment with regard to the tax deficiency, additions to tax, and interest that are the subject of R’s collection activities.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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