- 6 - F. Respondent’s Notice of Determination On August 9, 2001, respondent’s Appeals Office issued to petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 with regard to his tax liabilities for 1997 and 1998. In the notice, the Appeals Office concluded: the Notice of Filing of a Federal Tax Lien was legally and procedurally correct. There exists no basis for withdrawal of the Notice. G. Petitioner’s Petition On September 13, 2001, petitioner filed with the Court a Petition for Lien or Levy Action seeking review of respondent’s notice of determination.3 In the petition, there are no assignments of error or allegations of fact other than the terse statement that petitioner disagrees with “Penalties + Interest”. H. Respondent’s Motion For Summary Judgment As stated, respondent filed a Motion For Summary Judgment. Respondent contends that the petition contains nothing other than a challenge to the underlying liability (for interest and additions to tax), but that petitioner is precluded from pursuing such a challenge because he failed to raise that issue in the administrative hearing before the Appeals officer. 3 At the time that the petition was filed, petitioner resided in Houston, Texas.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011