-2-
$11,481.14, respectively.2 Currently, the case is before the
Court on respondent’s motion for summary judgment under Rule 121.
Although ordered to do so, petitioner did not file a response to
respondent’s motion.
We shall grant respondent’s motion for summary judgment.
Section references are to the applicable versions of the Internal
Revenue Code. Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
Petitioner failed to file 1992, 1994, 1995, and 1997 Forms
1120, U.S. Corporation Income Tax Return, and failed to file
Forms 941, Employment Tax Return, for the second and fourth
quarters of 2001. Petitioner filed untimely 2000 and 2001 Forms
1120.
On August 16, 2000, respondent mailed to petitioner a
letter, Final Notice--Notice of Intent to Levy and Notice of Your
Right to a Hearing (final notice). The final notice informed
petitioner of its tax liabilities for 1997 and 1998. The final
notice also informed petitioner of (1) respondent’s intent to
collect that liability through a levy upon its property under
section 6331 and (2) petitioner’s right under section 6330 to a
2 We use the term “approximately” because these amounts were
computed before the present proceeding and have since increased
on account of interest.
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Last modified: May 25, 2011