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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.
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