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On March 20, 2002, petitioner Russell L. Voorhees wrote a
letter to the Clerk of the Court requesting petition forms and
the rules for filing a petition. The Court received this letter
on April 1, 2002, and filed the letter as a Petition for Lien or
Levy Action under Code Section 6320(c) or 6330(d) (petition). By
order dated April 1, 2002, and directed to petitioner Russell L.
Voorhees only, this Court ordered the filing of a petition
complying with the requirements of Rule 331(b) and also required
payment of the filing fee. Thereafter petitioners submitted an
Amended Petition for Lien or Levy Action (amended petition) that
was filed on May 3, 2002. Both Russell L. and Ruth C. Voorhees
signed the amended petition. Both were residents of Arizona at
the time of the filing of the amended petition.
On May 30, 2002, respondent filed the motion to dismiss. On
June 12, 2002, petitioners filed a Response to Motion to Dismiss
and Strike as to Ruth C. Voorhees (response). Russell L.
Voorhees and Ruth C. Voorhees appeared at the hearing on
respondent’s motion to dismiss, and respondent was represented by
counsel.
Discussion
If any person liable to pay any tax neglects or refuses to
pay that tax within 10 days after notice and demand for payment,
the Secretary is authorized to collect the tax by levy upon the
person’s property. Section 6331(a). At least 30 days prior to
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Last modified: May 25, 2011