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This matter is before the Court on respondent’s Motion For
Summary Judgment, filed pursuant to Rule 121, as supplemented.
Respondent contends that there is no dispute as to any material
fact with respect to this levy action and that respondent’s
determination to proceed with collection of petitioners’
outstanding tax liability for the taxable year 2000 should be
sustained as a matter of law.
As explained in detail below, we shall grant respondent’s
motion, as supplemented.
Background
Petitioners resided in Bonner Springs, Kansas, at the time
that the petition was filed with the Court.
Petitioners timely filed their Form 1040, U.S. Individual
Income Tax Return, for 2000. On their return, petitioners listed
their address as 112 Lake Forest, Bonner Springs, Kansas 66012
(the Lake Forest address).2
Based on information provided by a third-party payor
indicating that petitioners might not have reported all of their
income on their 2000 return, respondent commenced an examination
of that return. On April 1, 2002, respondent sent petitioners a
2 Petitioners attached to their return a Schedule C, Profit
or Loss From Business, that also reflected the Lake Forest
address as the business address of petitioner James L. Geary. In
addition, petitioners attached to their return three Forms W-2,
Wage and Tax Statement, each of which showed the Lake Forest
address as petitioner Carol O. Geary’s address.
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Last modified: May 25, 2011