- 3 - and/or 6330 (notice of determination) regarding her 1991 tax year. In the notice of determination, respondent determined that the collection against petitioner should be sustained because petitioner did not file a joint return and, therefore, was not entitled to raise a spousal defense. On February 12, 2001, petitioner sent a letter to the Court regarding the notice of determination. The Court received the letter on February 16, 2001. The Court filed petitioner’s letter as a Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d) (petition). On March 14, 2001, the Court received petitioner’s amended petition, which was filed as an Amended Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d). On June 14, 2001, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not filed within the time prescribed by section 6330(d). Petitioner objected to this motion. On January 2, 2002, respondent filed a Motion to Withdraw Respondent’s Motion to Dismiss for Lack of Jurisdiction. On January 2, 2002, respondent also filed a Motion for Partial Summary Judgment on the issue of whether petitioner is eligible for relief under section 6015. On January 30, 2002, petitioner filed a response to respondent’s motion for partial summary judgment wherein petitioner objected to the granting of the motion.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011