Corona Pathology Services, Inc. - Page 4

                                         -4-                                          
          groceries, utilities, clothing, personal fitness, home pool                 
          supplies and services, magazine and newspaper subscriptions,                
          accounting and legal fees, and numerous cash withdrawals.  The              
          Appeals officer also reviewed an “Incomplete” Form 433,                     
          Collection Information Statement, that petitioner had filed with            
          the Commissioner as to its request to make installment payments.            
               On June 7, 2002, Appeals issued to petitioner a Notice of              
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 for 1997 and 1998 (notice of determination).  The               
          notice of determination reflected the determination of Appeals to           
          sustain the proposed levy on petitioner’s property.  The notice             
          of determination also reflected the determination of Appeals not            
          to accept petitioner’s request to make installment payments.  The           
          notice of determination stated that petitioner was out of                   
          compliance with its filing requirements and that it had                     
          commingled its funds with its shareholders and the funds of a               
          related corporation.                                                        
                                     Discussion                                       
               Summary judgment may be granted with respect to all or any             
          part of the legal issues in controversy if it is shown that there           
          is no genuine issue as to any material fact and that a decision             
          may be rendered as a matter of law.  Rule 121(a) and (b);                   
          Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd.            
          17 F.3d 965 (7th Cir. 1994).  We conclude that there is no                  






Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011