- 2 - 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.”Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011