- 8 - provided petitioner with a copy of the Court’s opinion in Pierson v. Commissioner, 115 T.C. 576 (2000). E. Respondent’s Notice of Determination On October 31, 2001, respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The notice stated that the Appeals Office had determined that it was appropriate for respondent to proceed with the collection of petitioner’s outstanding tax liability for 1997. F. Petitioner’s Petition On December 3, 2001, petitioner filed with the Court a petition for lien or levy action seeking review of respondent’s notice of determination.4 The petition includes allegations that: (1) The Appeals officers 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); (2) petitioner never received a notice and demand for payment or valid notice of deficiency; and (3) petitioner was denied the opportunity to raise “relevant issues”. G. Respondent’s Motion for Summary Judgment As indicated, respondent filed a Motion For Summary Judgment And To Impose A Penalty Under I.R.C. Section 6673 asserting that 4 At the time that the petition was filed, petitioner resided in Las Vegas, Nevada.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011