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of determination stated in pertinent part that the Secretary had
complied with all applicable laws and administrative procedures
in the examination, assessment, and collection actions taken in
the matter, the Appeals officer assigned to the matter had no
prior involvement with respect to petitioner’s tax liabilities,
and the Appeals Office would not consider petitioner’s challenge
to the existence of her tax liabilities because her arguments
were based on political, constitutional, conscientious, or
similar grounds.
Petitioner filed with the Court a Petition for Lien or Levy
Action Under Code Section 6320(c) or 6330(d) seeking review of
respondent’s notice of determination.2 Petitioner subsequently
filed an amended petition that included allegations that
respondent failed to obtain verification from the Secretary that
the requirements of any applicable law or administrative
procedure were met as required under section 6330(c)(1) and
respondent failed to consider whether petitioner is liable for
Federal income taxes.
After respondent filed an answer to the amended petition,
petitioner filed a motion for summary judgment asserting that
there is no dispute as to a material fact and petitioner is
2 At the time the petition was filed, petitioner was
residing in Allen, Tex.
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Last modified: May 25, 2011