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