- 6 - 6330(d) seeking review of respondent’s determination to proceed with collection of petitioner’s 1996, 1997, and 1998 tax liabilities. On April 2, 2002, the Court ordered petitioner to file a proper amended petition on or before April 30, 2002. Attached to the order were our Rules pertaining to lien and levy actions. On May 6, 2002, petitioner filed an amended petition for lien or levy action under Code section 6320(c) or 6330(d). Attached to the amended petition are, among other things, a transcript of the hearing and copies of petitioner’s transcripts of account for the years in issue. On February 21, 2003, respondent filed the motion for summary judgment. Attached as exhibits to the motion for summary judgment, among other things, are the transcript of the hearing and transcripts of petitioner’s accounts for 1996, 1997, and 1998. On February 24, 2003, the Court ordered petitioner to file a response to respondent’s motion for summary judgment on or before March 14, 2003. Petitioner did not file a response to respondent’s motion for summary judgment. Discussion Section 6320 provides that the Secretary shall furnish the person described in section 6321 with written notice (i.e., the hearing notice) of the filing of a notice of lien under sectionPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011