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MEMORANDUM OPINION
WHERRY, Judge: This case is before the Court on
respondent’s motion for summary judgment pursuant to Rule 121.1
The instant proceeding arises from a petition for judicial review
filed in response to a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330. The issue
for decision is whether respondent may proceed with collection
action as so determined.
Background
Petitioner filed Forms 1040, U.S. Individual Income Tax
Return, for the taxable years 1997, 1998, and 1999, using the
filing status of married filing separately. The 1997 return was
filed on August 28, 2002, and reported a tax liability of
$1,631.2 The 1998 return was filed on August 20, 2002, and
reported a tax liability of $7,853. The 1999 return was filed on
August 28, 2002, and reported a tax liability of $4,086. For the
taxable year 2001, petitioner filed a joint return with Kathryn
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
2 We note that respondent’s motion for summary judgment
contains apparently inadvertent errors in listing for each tax
year the same date for the filing of the return and the
assessment of the reported liabilities. The attached transcripts
of account for each year show the correct dates.
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