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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.
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