Miriam-Majadillas Eiselstein - Page 6




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          petitioner’s accounts for 1996, 1997, and 1998.                             
               On November 8, 2002, the Court ordered petitioner to file a            
          response to respondent’s motion for summary judgment on or before           
          December 9, 2002.  Petitioner did not file a response to                    
          respondent’s motion for summary judgment.                                   
          Discussion                                                                  
               Section 6320 provides that the Secretary shall furnish the             
          person described in section 6321 with written notice (i.e., the             
          hearing notice) of the filing of a notice of lien under section             
          6323.  Section 6320 further provides that the taxpayer may                  
          request administrative review of the matter (in the form of a               
          hearing) within a prescribed 30-day period.  The hearing                    
          generally shall be conducted consistent with the procedures set             
          forth in section 6330(c), (d), and (e).  Sec. 6320(c).                      
               The petition in this case is a 16-page document filled with            
          frivolous, tax-protester arguments.  Petitioner appears to                  
          challenge the underlying liability.  Petitioner received                    
          statutory notices of deficiency for each of the years in issue              
          and did not file a petition for redetermination.  Accordingly,              
          petitioner cannot contest the underlying deficiencies for 1996,             
          1997, and 1998.  Sec. 6330(c)(2)(B); Sego v. Commissioner, 114              
          T.C. 604, 610-611 (2000); Goza v. Commissioner, 114 T.C. 176,               
          182-183 (2000).                                                             
               Where the validity of the underlying tax liability is not              






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