- 11 - tax liability. Under the circumstances of this case, petitioner was provided with a hearing and opportunity to be heard as contemplated within the meaning of sections 6320 and 6330. Accordingly, we hold that respondent is entitled to proceed with enforced collection activity of petitioner’s 1994 income tax liability. To reflect the foregoing, An order and decision will be entered granting respondent’s motion for summary judgment.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
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