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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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Last modified: May 25, 2011