- 2 - 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 requestPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011