- 2 - 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 LienPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011