Early Robertson, Jr. - Page 2

                                        - 2 -                                         

               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.                                    
               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.                                  

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011