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121(a). Petitioner responded to respondent’s motion under Rule
121(b).
We shall grant respondent’s motion for summary judgment.
Section references are to the applicable versions of the Internal
Revenue Code. Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
Petitioner filed a delinquent Federal income tax return for
1989. Respondent sent a notice of deficiency to petitioner with
respect to his income tax liability for that year. Petitioner
then petitioned the Court contesting his liability specified in
the notice of deficiency. Because the petition was not filed
within the time prescribed by section 6213(a) or 7502, we
dismissed the case for lack of jurisdiction.
On or about April 18, 1994, an income tax deficiency and
related penalties and interest were assessed against petitioner
with respect to 1989. Petitioner failed to pay fully the amounts
assessed. On or about May 7, 2001, respondent issued to
petitioner a letter entitled “Final Notice - Notice of Intent to
Levy and Notice of Your Right to a Hearing Under IRC 6330".
On or about June 8, 2001, petitioner submitted a Form 12153,
Request For A Collection Due Process Hearing. On January 10,
2002, petitioner submitted an offer in compromise and a
collection information statement in connection with his request
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