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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 section
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