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certified as required by the Uniform Federal Tax Lien
Registration Act as adopted by the State of Nevada; (2) the
Appeals officer conducted a sham hearing; (3) petitioner was
denied a fair hearing by an impartial Appeals officer; (4) the
Appeals officer failed to obtain verification from the Secretary
that the requirements of any applicable law or administrative
procedure were met as required under section 6330(c)(1); (5) the
Appeals officer failed to identify the statutes (a) making
petitioner liable for Federal income tax; (b) authorizing
respondent’s agents to enforce the Internal Revenue Code; and (c)
permitting respondent to file a Notice of Federal Tax Lien; (6)
respondent falsely claimed that petitioner earned foreign source
income during 1995 and respondent failed to identify the specific
source of such income; and (7) petitioner was denied the
opportunity to challenge (a) the appropriateness of the
collection action; and (b) the existence or amount of his
underlying tax liability.
After filing an answer to the amended petition, respondent
filed a Motion for Summary Judgment asserting that there is no
dispute as to a material fact and that respondent is entitled to
judgment as a matter of law. In particular, respondent contends
that because petitioner received a notice of deficiency for 1995,
petitioner is barred under section 6330(c)(2)(B) from challenging
the existence or amount of his tax liability in this proceeding.
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Last modified: May 25, 2011