- 6 - Concerning Collection Actions(s) Under Section 6320 and/or 6330 was issued to petitioner on May 14, 2003. The notice summarized respondent’s determination: “You proposed an offer in compromise in the amount of $15,000 as your collection alternative. We must reject your offer because you failed to submit the additional information requested which was needed to make a determination regarding the acceptance of your offer. Levy action is, therefore, appropriate.” An attachment to the notice provided further details and indicated that, beyond the proposed collection alternative, “No other issues were raised” by the taxpayer. Petitioner’s petition challenging this notice of determination was filed with the Tax Court on June 11, 2003, and reflected an address in Marlton, New Jersey. Petitioner contends in the petition that he did not receive a fair hearing as required by section 6330, and that respondent erred in rejecting petitioner’s offer in compromise, due to respondent’s decision that “‘Six weeks of silence’ amounts to a ‘failure to submit the requested documents’”. Respondent prepared and filed an answer to the petition and subsequently filed the subject motion for summary judgment. Petitioner filed a response to respondent’s motion.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011