- 12 -
of the 1995 income tax liability.
We uphold the Appeals officer’s determination that the
filing of a tax lien was an appropriate enforcement action with
respect to petitioner’s 1995 and 1996 income tax liabilities. We
shall grant respondent’s motion for summary judgment and sustain
the notice of determination dated February 19, 2002.
For the reasons stated and to reflect the foregoing,
An appropriate order and
decision will be entered.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011