- 5 - Officer Mountjoy that he no longer believed that petitioner was entitled to an installment agreement because she was not in compliance with her filing and paying requirements for 2001. The conversation reconfirmed Appeals Officer Mountjoy’s prior conclusion that it was not in the Government’s interest to accept the proposed installment plan. On May 10, 2002, respondent issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 to petitioner regarding her 1997 and 1999 tax years (notice of determination). In the notice of determination, respondent determined that the issuance of the notice of intent to levy and proposed collection action were appropriate. In the attachment to the notice of determination, respondent explained: “Since you are not in compliance with the current filing and paying requirement for current taxes [2001], you do not qualify for an installment payment plan.” On June 17, 2002, petitioner timely filed a petition for lien or levy action under Code section 6320(c) or 6330(d) seeking review of respondent’s determination to proceed with collection of petitioner’s 1997 and 1999 tax liabilities.2 On November 20, 2002, respondent filed a motion for summary judgment. On November 21, 2002, the Court ordered petitioner to 2 At the time she filed the petition, petitioner resided in Anacortes, Washington.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011