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for Individuals, suggesting that petitioner submit an offer in
compromise on or before December 29, 2001. Petitioner failed to
submit the forms before the December 29, 2001, deadline.
Respondent mailed petitioner a notice of determination
concerning collection action(s) under section 6320 and/or section
6330 (notice of determination), dated February 19, 2002,
determining that the filing of the tax lien was an appropriate
enforcement action.
Petitioner’s Petition
Petitioner filed a timely petition contesting respondent’s
notice of determination on March 15, 2002.2 Although
respondent’s notice of determination dealt solely with
petitioner’s income tax liabilities for the taxable years 1995
and 1996, petitioner disputed her income tax liabilities for 1993
through 1996 in her petition. On May 8, 2002, respondent filed a
Motion to Dismiss for Lack of Jurisdiction and to Strike As to
Taxable Years 1993 and 1994. This Court granted respondent’s
motion by order dated June 12, 2002, dismissing the case as to
the taxable years 1993 and 1994 and striking references to those
years from the petition.
After the 1993 and 1994 references were stricken,
petitioner’s two remaining allegations are that she paid “over
2At the time she filed the petition, petitioner resided in
Clinton, Md.
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