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of Federal tax lien and denied relief to Ms. Dixon under section
6015(b), (c), or (f).
Petitioners’ petition challenging these notices was filed
with the Tax Court on March 3, 2003, and reflected an address for
Ms. Dixon at 1628 Gilda Circle, Mobile, Alabama 36618, and for
Mr. Dixon at 559 Sweeney Lane, Mobile, Alabama 36617. The
petition contains two counts. Count one states:
Petitioners disagree with the determination
concerning requests for relief from joint and several
liability under Section 6015, dated January 27, 2003,
on grounds that the taxpayer was unaware of any
unreported income as her husband and her father-in-law
handled all of the details of the income in question.
Count two reads:
Petitioners disagree with the determination
concerning collection actions under Sections 6320
and/or 6330 in that there was no unreported non-
employee compensation as set forth in the determination
as this was not money earned by either of the
Petitioners.
Respondent then filed the subject motion for partial summary
judgment on September 5, 2003. Respondent asks for summary
judgment with respect to the propriety of the Notices of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 in that “petitioners’ receipt of the statutory notice
of deficiency precludes challenging the underlying tax liability
for the taxable year 1997, the only error assigned in the
petition as to the collection due process issue.” Petitioners
were ordered to file any response to respondent’s motion on or
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