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