- 4 -
1993 and 1994. On March 31, 2003, petitioner timely filed a
second Form 12153 for taxable years 1993, 1994, and 2000.
On May 22, 2003, a telephone conference was held between
petitioner and a settlement officer at respondent’s Office of
Appeals. In a letter dated May 23, 2003, the settlement officer
confirmed the above telephone conversation and petitioner’s
request to handle her case and conduct her hearing by telephone
and correspondence due to her health.
After the telephone conference, the settlement officer
requested additional financial information from petitioner and
provided her with a copy of MFTRA-X Transcripts for petitioner’s
tax liabilities for taxable years 1993, 1994, and 2000. In a
letter dated July 30, 2003, the settlement officer notified
petitioner that, based on the information provided by petitioner,
he could not recommend acceptance of petitioner’s offer in
compromise, and he provided his specific reasoning.
On December 4, 2003, respondent’s Office of Appeals issued
to petitioner a Notice of Determination Concerning Collection
Action(s) Under Code Section 6230(c) or 6330(d).
Discussion
I. General Rules
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). Summary judgment is
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011