- 2 - 6330(d)(1).1 Petitioner filed an objection to respondent's motion. The parties then filed seriatim responses to petitioner's objection. A hearing was held on respondent's motion. Petitioner, who is incarcerated, did not appear but instead submitted a statement under Rule 50(c). Respondent offered the testimony of the settlement officer who handled petitioner's request for a hearing under section 6330. We base our findings on the facts that are not in dispute, petitioner's submissions, and various documents from petitioner's administrative file in the record. We rely on respondent's witness's testimony only to the extent it contains admissions or establishes the foundation for admitting the material in petitioner's administrative file. Background Petitioner was incarcerated at Oakhill Correctional Institution in Oregon, Wisconsin, at the time the petition was filed. On April 30, 2002, a Final Notice - Notice of Intent to Levy and Notice of Your Right to a Hearing, was mailed to petitioner at 3401 West Wanda Avenue, Milwaukee, Wisconsin ("Wanda Avenue address"), regarding unpaid Federal income taxes for 1991. On 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011