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B. The Section 6320(b) Hearing and Respondent’s Notice of
Determination
On March 28, 2001, respondent’s Appeals Office conducted a
hearing under section 6320(b) in petitioner’s case relating to
assessments of his income tax liabilities for tax years 1986,
1988, 1989, 1995, 1996, and 1998. Petitioner attended the
hearing. At the hearing, petitioner questioned whether an
Assessment officer had signed the assessment documents for the
years in issue. The Appeals officer gave petitioner a copy of a
Form 4340, Certificate of Assessments and Payments, for each of
the years in issue. Petitioner did not challenge the
appropriateness of the intended method of collection.
On May 17, 2001, respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (the determination letter), in which respondent
stated that collection from petitioner of his tax liability for
tax years 1986, 1988, 1989, 1995, 1996, and 1998 would proceed.
On June 20, 2001, petitioner filed a petition for lien or levy
action under section 6320(c) or section 6330(d).
Discussion
A. Summary Judgment
We may grant summary judgment if there is no genuine issue
of material fact and a decision may be rendered as a matter of
law. Rule 121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518,
520 (1992), affd. 17 F.3d 965 (7th Cir. 1994); Zaentz v.
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Last modified: May 25, 2011