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On April 11, 2002, respondent sent petitioners a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (the determination letter), in which respondent
denied petitioners’ request for relief.
On May 14, 2002, petitioners filed a petition for lien or
levy action under section 6320(c) or 6330(d). In their petition,
petitioners contended only that: (1) Respondent erred in trying
to collect from petitioners employment taxes owed by petitioner’s
law corporation; and (2) respondent failed to send to their last
known address any notice of the Federal tax liens filed in 1992
and 1997. Petitioners did not propose any alternatives to
collection in their petition.
Respondent filed a motion for summary judgment. The Court
ordered petitioners to file a response to respondent’s motion,
but they did not do so.
Discussion
A. Summary Judgment
Summary judgment is intended to expedite litigation and to
avoid the need for expensive trials. Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). We may grant summary
judgment if the pleadings, answers to interrogatories,
depositions, admissions, affidavits, and any other acceptable
materials show that there is no genuine issue of material fact
and a decision may be rendered as a matter of law. Rule 121(b);
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Last modified: May 25, 2011