John J. Green - Page 2




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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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