- 2 - MEMORANDUM OPINION NIMS, Judge: This case is before us on petitioner’s motion to dismiss for lack of jurisdiction. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended. The issue for decision is whether this Court has jurisdiction to review respondent’s determination to proceed with collection of assessed Federal income tax liabilities for petitioner’s taxable year 1996. Background Respondent issued a “NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330” to petitioner on November 1, 2001. The notice states: Mr. Green was mailed a Statutory Notice of Deficiency on 9/7/99. * * * * * * * * * * The tax assessment was made on 4/10/2000. An initial balance due notice was sent to the taxpayer at the same address of record on 4/10/2000. * * * the taxpayer did not pay the subject assessment within 10 days. The three aspects of IRC 6321 were met, thus the statutory lien arose. * * * * * * * On 6/19/2001 a conference was held with Mr. Green at the Olympia Fields, Illinois field office. * * * He did not propose an alternative to the filed lien. He questioned the under-lying assessment and whether or not the Service had followed proper procedures in making the subject assessment. The Settlement Officer explained the Statutory Notice of Deficiency had beenPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011