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OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: This collection review case is
before the Court on respondent’s motion to dismiss for lack of
jurisdiction. Respondent contends that the Court lacks
jurisdiction on the ground the petition for lien or levy action
was not timely filed. As discussed in detail below, we shall
dismiss the petition for lack of jurisdiction.
Background
The record reflects and/or the parties do not dispute the
following facts:
On December 19, 2002, respondent mailed to petitioner a
Notice Of Determination Concerning Collection Action(s) informing
petitioner that respondent would proceed with the collection of
petitioner’s unpaid Federal income taxes for 1992, 1993, 1994,
and 1995 (the income tax notice). On December 19, 2002,
respondent also mailed to petitioner a Notice Of Determination
Concerning Collection Action(s) informing petitioner that
respondent would proceed with the collection of petitioner’s
unpaid liability for a civil penalty imposed under section 6682
for the taxable period ending December 31, 1997 (the civil
penalty notice).2
2 Sec. 6682(a) generally provides that an individual shall
be liable for a civil penalty if such individual is found to have
made a false statement regarding the correct amount of income tax
withholding on wages and/or backup withholding.
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Last modified: May 25, 2011