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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.
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