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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.
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Last modified: May 25, 2011