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On April 7, 2001, petitioner filed an amended U.S.
individual income tax return for 1995. Petitioner reported zero
income and zero taxes due, explaining the changes: “Due to
ignorance I reported as income sources of income as being income
itself, when in fact I had no statutory income to report.”
On October 12, 2001, Appeals Officer Julienne Peterson held
with petitioner a hearing under section 6330. At the hearing,
the Appeals officer provided petitioner with Forms 4340,
Certificates of Assessments, Payments and Other Specified
Matters. The Forms 4340 were dated August 29, 2001, and were for
1993, 1995, and 1996. The Appeals officer discussed with
petitioner the case of Pierson v. Commissioner, 115 T.C. 576
(2000), and provided petitioner with a copy of the Court’s
opinion in that case. The Appeals officer also gave petitioner a
copy of this Court’s opinion in Davis v. Commissioner, T.C. Memo.
2001-87.
On January 3, 2002, respondent issued to petitioner a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330 for 1993, 1995, and 1996. This notice reflected
the determination of Appeals to sustain the lien and proposed
levy.
Discussion
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. Fla. Peach Corp. v.
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