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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 been
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