- 2 - This matter is before the Court on respondent’s motion for summary judgment, filed pursuant to Rule 121. As explained in more detail below, we shall grant such motion in part and deny the motion in part. We shall also, on the Court’s own motion, dismiss for lack of jurisdiction and strike as to the taxable years 1997, 1998, and 1999. Background The record reflects and/or the parties do not dispute the following facts. On November 10, 2000, respondent sent to petitioner a notice of intent to levy regarding unpaid income tax liabilities for 1997, 1998, and 1999. Petitioner did not request an Appeals Office hearing with respect to this notice. On April 10, 2002, respondent sent to petitioner a notice of intent to levy regarding unpaid income tax liability for 2000. Petitioner timely requested an Appeals Office hearing with respect to the April 10, 2002, notice. During the period November 2002 through part of July 2003, representatives of the IRS unsuccessfully attempted to contact petitioner by telephone and letter. A July 1, 2003, letter from the IRS Appeals Office advised petitioner that he was entitled to a hearing for the 2000 tax year pursuant to section 6330. The letter further advised that since a timely request for hearing was not made for 1997, 1998, and 1999, an equivalent hearing would be permitted as to those years. However, the letterPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011