- 3 - taxable years 1991 and 1992, and that respondent was preparing to collect this amount by levy. The notice stated that petitioner had 30 days to request a collection due process hearing with respondent's Appeals Office. On November 10, 1999, petitioner filed a request for a section 6330 hearing with respondent's Appeals Office. On November 20, 2000, the Appeals Office conducted a hearing in petitioner’s case. On December 12, 2000, respondent's Appeals Office issued to petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (the determination letter). The determination letter stated that the Appeals Office would proceed with collection with respect to the amount due for 1991, but that petitioner was not liable for any amount for 1992. Respondent’s determination to abate the assessments entered against petitioner for 1992 produced a credit of $50 for that year which respondent applied to petitioner’s outstanding tax liability for 1991. On January 9, 2001, petitioner filed with the Court an imperfect Petition for Lien or Levy Action Under Section 6320(b) or 6330(d).2 On March 26, 2001, petitioner filed an amended petition which included nothing but frivolous and groundless 2 At the time the petition was filed, petitioner resided in Las Vegas, Nevada.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011