Janice Bullock - Page 6




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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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