Willie R. Davidson - Page 8




                                        - 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