Carl R. Neugebauer - Page 2

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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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