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.
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