- 5 - On October 12, 2000, respondent received petitioner’s Form 12153, Request for a Collection Due Process Hearing. On February 13, 2002, a face-to-face hearing was held between an Appeals officer and petitioner. During the hearing, petitioner was provided with a Form 4340, Certificate of Assessments, Payments, and Other Specified Matters for his 1995, 1996, and 1997 tax years. The Appeals officer also informed petitioner that the arguments he made at the hearing were considered to be frivolous. The hearing was recorded and transcribed. On March 8, 2002, respondent issued two Notice(s) of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 advising that respondent determined to proceed with collection. Attached to the notices were the Appeals officer’s report, denominated as a “Summary of Issue and Recommendation”, which included advice to petitioner that the Tax Court is authorized “to impose monetary sanctions up to $25,000 for instituting or maintaining an action before it primarily of [sic] delay or for a [sic] taking a position that is frivolous or groundless.” Discussion Respondent seeks summary judgment with respect to whether he may proceed to collect certain outstanding tax liabilities 2(...continued) his petition to this Court, petitioner did not challenge respondent’s actions with respect to the 1998 liability.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011