Sue Taylor - Page 2

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          whether this case should be remanded to respondent’s Appeals                
          Office for a recorded administrative hearing.  Petitioner objects           
          to respondent’s motion, and respondent objects to petitioner’s              
          motion.  All section references are to the Internal Revenue Code            
          in effect for the year in issue, and all Rule references are to             
          the Tax Court Rules of Practice and Procedure, unless otherwise             
          indicated.                                                                  
          Background                                                                  
               On June 21, 2001, respondent mailed to petitioner a                    
          statutory notice of deficiency for the taxable period ending                
          December 31, 1997.  Petitioner received the statutory notice, but           
          failed to petition this Court.  On November 26, 2001, respondent            
          assessed petitioner’s 1997 Federal income tax deficiency.                   
               A Form 1058, Final Notice--Notice of Intent to Levy and                
          Notice of Your Right to a Hearing, was sent to petitioner on                
          April 2, 2002.  On April 9, 2002, respondent sent petitioner a              
          letter entitled, “Notice of Federal Tax Lien Filing and Your                
          Right to a Hearing under I.R.C. �6320”.  Petitioner’s designated            
          representative timely requested an administrative hearing under             
          sections 6320 and 6330.  Petitioner’s sole contention in the                
          administrative hearing request was that “there are egregious                
          errors that once corrected would mitigate the collection                    
          activity.”                                                                  








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