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Respondent issued to petitioner a notice of determination
that sustained the proposed use of a levy to collect petitioner’s
unpaid Federal income tax liabilities for taxable years 1997 and
2000. In the notice of determination, respondent concluded that
petitioner had not verified that he qualifies for currently not
collectible status or any other type of collection alternative.
2. The Petition and Motion
Petitioner submitted to this Court a timely petition
appealing respondent’s determination. Therein, petitioner
specified that he does not challenge the amount of the underlying
tax liabilities. He challenges the “appropriateness of
collection actions based on circumstances, etc” and the “offers
of collection alternatives as listed without reference to the law
as written and efforts to settle by citizen (L Brown)(sic).”
Respondent moved for summary judgment. The Court ordered
respondent’s motion set for hearing at the call of the calendar
in Los Angeles. After the hearing, the Court denied respondent’s
motion for summary judgment.
Discussion
Section 6330(a) provides that no levy may be made on any
property or right to property of any person unless the Secretary
has notified such person in writing of the right to a hearing
before the levy is made. If the person makes a request for a
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Last modified: May 25, 2011