Thomas G Collier - Page 2

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                                 MEMORANDUM OPINION                                   

               WHERRY, Judge:  This case is before the Court on                       
          respondent’s motion for summary judgment pursuant to Rule 121.1             
          The instant proceeding arises from a petition for judicial review           
          filed in response to a Notice of Determination Concerning                   
          Collection Actions(s) Under Section 6320 and/or 6330.  The issue            
          for decision is whether respondent may proceed with collection              
          action as so determined.                                                    
                                     Background                                       
               Petitioner filed Federal income tax returns for 1995, 1997,            
          1998, and 1999 and did not fully pay the reported liabilities.              
          Respondent subsequently assessed the reported amounts, along with           
          statutory additions, and sent to petitioner notices of balance              
          due.  Respondent then issued to petitioner a Final Notice -                 
          Notice of Intent to Levy and Notice of Your Right to a Hearing              
          dated February 2, 2002, with regard to the 1995, 1997, 1998, and            
          1999 years.  The notice reflected a total amount due of                     
          $51,373.49, which amount included statutory additions.                      
               In response to the notice, petitioner’s representative, C.             
          Page Hamrick III (Mr. Hamrick), timely submitted a Form 12153,              
          Request for a Collection Due Process Hearing, received by                   


               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code of 1986, as amended, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            





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