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Petitioner was given the opportunity during the hearing to
present collection alternatives, but he refused.
In the January 8, 2002, Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 for 1998
(notice of determination) sent to petitioner, the Appeals officer
determined that “all of the legal and procedural requirements for
taking levy action have been met”, and collection could proceed.
On January 31, 2002, petitioner and his wife filed a
petition with the Court for judicial review of respondent’s
notice of determination. The petition contained only tax-
protester arguments. On April 16, 2002, the Court granted
respondent’s motion to dismiss for lack of jurisdiction as to
petitioner’s wife because she failed to sign the Form 12153 and
the notice of determination only pertained to petitioner.
Sometime before February 3, 2003, petitioner submitted an
offer in compromise, which was rejected by respondent’s Offer in
Compromise Group.
On August 17, 2004, respondent filed a motion for summary
judgment. By order dated August 18, 2004, petitioner was given
until September 10, 2004, to file a response to the motion for
summary judgment. To date, no response has been received by the
Court from petitioner.
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Last modified: May 25, 2011