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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.
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Last modified: May 25, 2011