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entitled to judgment as a matter of law. Petitioner maintains
that respondent’s notice of determination is arbitrary and
capricious and that the Appeals officer failed to consider
properly petitioner’s assertion that she did not receive income
from a taxable source during 1995 and 1996.
Respondent filed an objection to petitioner’s motion.
Respondent also filed a motion for summary judgment. Respondent
contends that petitioner failed to raise any valid claims with
respect to the existence or amount of her tax liabilities for
1995 and 1996. Respondent further asserts that the Appeals
officer properly verified that the requirements of all applicable
laws and administrative procedures were met with regard to the
assessment and collection actions taken in this case. Petitioner
filed an objection to respondent’s motion.
This matter was called for hearing at the Court’s motions
session held in Washington, D.C. Counsel for respondent appeared
at the hearing and presented argument in support of respondent’s
motion. No appearance was made by or on behalf of petitioner at
the hearing, nor did petitioner file with the Court a written
statement pursuant to Rule 50(c).
Discussion
Section 6331(a) provides that, if any person liable to pay
any tax neglects or refuses to pay such tax within 10 days after
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Last modified: May 25, 2011