- 7 -
And so their motion for summary judgment was
denied. At this trial today, there is a verbatim
record being made, and if you have any other issues
that you wish to raise other than those that were in
your previous documents, this is your chance to raise
them.
If you don’t raise what I deem to be a legitimate
issue under Section 6330(c)(2), which I have
jurisdiction to consider, and I rule against you, then
other than your right to appeal to a Circuit Court of
Appeals, your case will be over.
So if you have any other additional issues that
you wanted to raise or discuss with the Appeals
Officer, you need to raise them here today so that I
can determine if this case should be remanded to
appeals to consider those issues, or if there is not
reason to remand the case because there is [sic] no
issues that I can’t adequately dispose of here at this
trial. All right?
The sole new issue specifically raised by petitioner at
trial was that the filing of the notice of tax lien was invalid
because he did not receive proper notification of this action
from respondent. Petitioner testified that he instead learned of
the filing from a credit watch service to which he subscribes and
which alerts him of adverse activity concerning his credit
report.
The parties subsequently filed posttrial briefs. Petitioner
recapitulated the position taken throughout these proceedings and
at trial, focusing once again on lack of a recorded hearing and
of sufficient notification, verification, and documentation of
procedural requisites.
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Last modified: May 25, 2011