Janie M. Dixon and Joseph Dixon, Jr. - Page 3

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          filed in response to:  (1) Separate Notices of Determination                
          Concerning Collection Action(s) Under Section 6320 and/or 6330              
          sent to petitioner Janie M. Dixon (Ms. Dixon) and to petitioner             
          Joseph Dixon, Jr. (Mr. Dixon); and (2) a Notice of Determination            
          Concerning Your Request for Relief from Joint and Several                   
          Liability Under Section 6015 sent to Ms. Dixon.  Respondent moves           
          for partial summary judgment with respect to collection issues              
          other than Ms. Dixon’s request for spousal relief.  The section             
          6015 claim will be dealt with separately at a later date.                   
                                     Background                                       
               On January 7, 2000, respondent issued to petitioners a                 
          notice of deficiency for the taxable year 1997.  The notice                 
          reflected a deficiency of $13,230 and an accuracy-related penalty           
          under section 6662 of $2,646.  The notice was sent by U.S.                  
          certified mail to petitioners at 1628 Gilda Circle, Mobile,                 
          Alabama 36618-1842281.  Petitioners did not file a petition with            
          the Tax Court in response to the notice of deficiency, and                  
          respondent assessed the deficiency, penalty, and $2,921.22                  
          interest on May 29, 2000.                                                   
               On December 29, 2000, respondent filed a Notice of Federal             
          Tax Lien with the Judge of Probate, Mobile County, Alabama,                 
          listing petitioners’ income tax liabilities for 1997.  The unpaid           
          balance was shown as $18,797.22.  Thereafter, on January 4, 2001,           
          respondent sent to petitioners a Notice of Federal Tax Lien                 






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