- 5 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011