Scott William Katz - Page 1

                                   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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