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dismissing petitioner’s bankruptcy case due to her failure to
file required schedules. On December 6, 2001, the bankruptcy
court entered an order closing petitioner’s case.
In the meantime, on December 5, 2001, petitioner filed a
second bankruptcy petition.
On December 19, 2001, petitioner filed with respondent a
Form 12153, Request for a Collection Due Process Hearing,
challenging the proposed levy.
On May 17, 2002, the bankruptcy court dismissed petitioner’s
second bankruptcy case.
On June 5, 2003, respondent issued to petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (notice of determination) which stated that
respondent intended to proceed with the proposed levy. On July
7, 2003, petitioner filed with the Court a Petition for Lien or
Levy Action challenging respondent’s notice of determination.3
At the time the petition was filed, petitioner resided in
Collinsville, Illinois.
As indicated, respondent filed a Motion for Summary
Judgment. Respondent contends that the Court should sustain the
notice of determination on the ground that the Appeals officer
did not abuse her discretion in rejecting petitioner’s offer in
3 The petition arrived at the Court in an envelope bearing
a timely U.S. Postal Service postmark dated July 1, 2003. See
sec. 7502(a).
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Last modified: May 25, 2011