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liability for one year by crediting refunds from other years did
not violate section 6015(e)(1)(B), which bars levy actions while
a taxpayer’s claim for relief from joint and several liability on
a joint return is pending); sec. 301.6330-1(g)(2), Q&A-G3,
Proced. & Admin. Regs.
In sum, we shall grant respondent’s motion to dismiss and to
strike, as supplemented, inasmuch as respondent has not issued a
notice of determination to petitioner with regard to any
collection action for either 1991 or 1992.
To reflect the foregoing,
An order will be issued granting
respondent’s motion to dismiss for
lack of jurisdiction and to strike, as
supplemented.
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Last modified: May 25, 2011