- 7 - Petitioner, in his petition, generally alleged that he disagrees with the amount of the tax and that he would like to pay under an installment agreement. The petition does not contain specific assignments of error or any statements of alleged facts. See Rule 331(b)(4) and (5). Petitioner also failed to set forth facts showing that there is a material or specific question regarding the amount of his underlying liability. In addition, the Appeals officer considered petitioner for an offer-in-compromise but determined he was not eligible, and petitioner does not contest that determination. Petitioner did not contend that the Appeals officer failed to comply with any other applicable law, and he did not raise any other relevant issue such as spousal defenses, challenges to the appropriateness of collection actions, or other collection alternatives. Accordingly, there exists no issue of material fact in this case, and respondent is entitled to summary judgment. Respondent is therefore entitled to proceed with collection activity. To reflect the foregoing, An appropriate order and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011