- 5 - determination stated that petitioner would not be granted relief pursuant to section 6330 because, among other things, petitioner did not appear at the scheduled section 6330 hearing and did not present any documentation to challenge the assessed tax liabilities. The notice of determination further stated that the 10-year period of limitations for collecting petitioner’s 1989 tax liability was still open and that respondent’s transcripts of petitioner’s account did not show that any payments had been made with respect to petitioner’s taxable years 1990, 1992, 1993, 1996, or 1997, and that only two payments (both in 1993) had been made with respect to petitioner’s 1991 taxable year. On June 16, 2000, in response to the notice of determination, petitioner filed with the Court an imperfect petition. On August 15, 2000, petitioner filed an amended petition, disputing respondent’s determinations on grounds that: (1) The applicable period of limitations bars collection for taxable years 1989 and 1990, and (2) the taxes owed for the taxable years 1991, 1992, 1993, 1996, and 1997 were previously paid. OPINION Section 6330 provides for notice and opportunity of a hearing before the Internal Revenue Service (IRS) may levy upon the property of any person. Section 6330(b)(1) provides that if the person requests a hearing, “such hearing shall be held by the Internal Revenue Service Office of Appeals.” SectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011