-4- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011