- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011