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penalties, and interest with respect to 1989, 1993, 1994, and
1996. On or about August 30, 2002, respondent released the lien
against petitioner for 1989, 1993, 1994, and 1996. Respondent no
longer intends to pursue any levy action against petitioner for
any income taxes, penalties, or interest for 1989, 1993, 1994,
and/or 1996 as they have been paid in full.
On November 4, 2003, respondent filed the motion. On
November 5, 2003, the Court ordered petitioner to file any
objection to the motion on or before November 19, 2003. On
November 18, 2003, petitioner filed an objection to the motion.
The Court heard argument on the motion.
Discussion
Our jurisdiction under section 6330 is generally limited to
reviewing whether the proposed lien or levy action is proper.
Chocallo v. Commissioner, T.C. Memo. 2004-152. Respondent
released the lien and has stated that he is no longer pursuing
the proposed levy. As the parties now agree that there is no
unpaid liability for 1989, 1993, 1994, or 1996 upon which a lien
or levy could be based, we agree with respondent that the case is
moot. Id.
We note that petitioner claimed respondent’s employees
mistreated him, respondent’s employees violated his civil rights,
and that his credit rating was adversely affected by the filing
of the lien. Petitioner did not cite or rely on any specific
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