Janice Bullock - Page 3




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          Action(s) Under Section 6320 and/or 6330.1  On March 28, 2002,              
          the Court received and filed a Petition for Lien or Levy Action             
          Under Code Sections 6320(c) or 6330(d).2  The petition lists the            
          years in dispute as 1991 through 1996.                                      
               As indicated, respondent moved to dismiss for lack of                  
          jurisdiction and to strike as to the taxable years 1991 and 1992.           
          Respondent contends that the Court lacks jurisdiction with regard           
          to 1991 and 1992 on the ground that respondent has not issued to            
          petitioner a notice of determination with regard to those years.            
          Respondent avers that the notice of determination dated February            
          19, 2002, on which the petition is based, pertains only to the              
          taxable years 1993 through 1996.  Petitioner filed an objection             
          to respondent’s motion, attaching to her objection copies of the            
          notices of levy for 1991 and 1992 that respondent served on the             
          City of Philadelphia and Corestates Bank (described above).                 
               This matter was called for hearing at the Court’s motions              
          session held in Washington, D.C.  Counsel for respondent appeared           
          at the hearing and offered argument in support of the motion to             
          dismiss.  There was no appearance by or on behalf of petitioner.            
          Following the hearing, respondent filed a supplement to his                 


          1  Unless otherwise indicated, all section references are to                
          the Internal Revenue Code, as amended.                                      
          2  The petition arrived at the Court in a properly addressed                
          envelope bearing a timely U.S. Postal Service postmark date of              
          Mar. 19, 2002.                                                              





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