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Early Robertson, Jr., pro se.
Marshall R. Jones and Robert W. West, for respondent.
MEMORANDUM OPINION
WHERRY, Judge: This case is before the Court on
respondent’s motion for summary judgment pursuant to Rule 121.
The instant proceeding arises from a petition for judicial review
filed in response to a Notice of Determination Concerning
Collection Actions(s) Under Section 6330 of the Internal Revenue
Code.1 The issue for decision is whether respondent may proceed
with collection action as so determined.
Background
On May 29, 1998, respondent issued to petitioner a notice of
deficiency for the 1995 and 1996 taxable years. The notice
reflected deficiencies of $2,911 and $3,013 in petitioner’s
income taxes for 1995 and 1996, respectively. Petitioner did not
file a petition with the Court contesting this deficiency notice.
Thereafter, on October 17, 2000, respondent issued to
petitioner a Final Notice--Notice of Intent to Levy and Notice of
Your Right to a Hearing with respect to unpaid tax liabilities
1 Unless otherwise indicated, section references are to the
Internal Revenue Code, as amended, and Rule references are to the
Tax Court Rules of Practice and Procedure.
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