- 5 - Ninth Circuit. Petitioner subsequently amended the petition to allege that the Appeals officer had failed, as required by section 6330(c)(1), to verify that all applicable laws and administrative procedures had been met; in particular, petitioner alleged that the liabilities had not been properly assessed and that he had not received notice of the assessments as required by section 6303. Subsequent to the filing of respondent’s motion for summary judgment and petitioner’s response, the Court of Appeals on February 14, 2003, affirmed our opinion in MatrixInfoSys Trust v. Commissioner, supra, sustaining the underlying tax liabilities that are the subject of this collection action, and entered judgment. Hromiko v. Commissioner, 56 Fed. Appx. 359 (9th Cir. 2003). Discussion Section 6331(a) provides that if any person liable to pay any tax neglects or refuses to pay such tax within 10 days after notice and demand, the Secretary may collect such tax by levy on the person’s property. Section 6331(d) provides that at least 30 days before enforcing collection by levy on the person’s property, the Secretary must provide the person with a final notice of intent to levy, including notice of the administrative appeals available to the person.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011