Shade D. Coleman III and Maria M. Coleman - Page 5

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          collection of petitioners’ outstanding tax liabilities.  On                 
          May 7, 2001, petitioners filed with the Court a joint petition              
          for lien or levy action seeking review of respondent’s notices of           
               As indicated, respondent filed a motion for summary judgment           
          asserting that there is no dispute as to a material fact and that           
          respondent is entitled to judgment as a matter of law.  In                  
          particular, respondent contends that, because petitioners                   
          acknowledge that they received the notice of deficiency dated               
          October 15, 1999, they cannot challenge the existence or amount             
          of their underlying tax liability for 1997 in this proceeding.              
          Respondent further asserts that the Appeals officer’s review of             
          Form 4340 with regard to petitioners’ account for 1997 satisfied            
          the verification requirement imposed under section 6330(c)(1) and           
          demonstrates that petitioners were issued a notice and demand for           
               Petitioners filed an objection to respondent’s motion.                 
          Thereafter, pursuant to notice, respondent’s motion was called              
          for hearing at the Court’s motions session in Washington, D.C.              
               Section 6331(a) provides that if any person liable to pay              
          any tax neglects or refuses to pay such tax within 10 days after            

               2  At the time that the petition was filed, petitioners                
          resided in Las Vegas, Nev.                                                  

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