Christopher Michael Frazier - Page 7

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               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.                                   








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