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petitioner a notice of determination concerning collection
actions that would allow petitioner to invoke the Court’s
jurisdiction under sections 6320 and/or 6330.1 As discussed in
detail below, we shall grant respondent’s motion to dismiss, as
supplemented.
Background
The record establishes and/or the parties do not dispute the
following:
A. Notice of Deficiency
On February 9, 2000, respondent mailed to petitioner a
notice of deficiency. In the notice of deficiency, respondent
determined deficiencies in petitioner’s Federal income taxes for
1996, 1997, and 1998 in the amounts of $73,516, $3,619, and
$4,549, respectively. Respondent also determined that petitioner
was liable for accuracy-related penalties under section 6662(a)
for 1996 and 1997 in the amounts of $14,703.20 and $723.80,
respectively.
The notice of deficiency was issued by the Internal Revenue
Service (IRS) District Director in Cincinnati, Ohio. The notice
of deficiency was signed “C. Ashley Bullard by BL”. At the time
that the notice of deficiency was issued, C. Ashley Bullard was
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011