- 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
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