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Petitioner filed with the Court on June 9, 2003, a timely
petition for lien and levy action.6 In the petition, petitioner
alleged that the notice of determination should be overturned on
the grounds that (1) the Appeals Office failed to verify that all
applicable laws and administrative procedures were satisfied, and
(2) petitioner's tax liabilities for the years in issue were
discharged in bankruptcy.
After filing an answer to the petition, respondent filed a
motion for summary judgment. Respondent asserted that the
Appeals Office properly verified that all applicable laws and
administrative procedures were met with regard to the assessments
and proposed collection actions in dispute. In support of this
assertion, respondent attached to his motion Forms 4340,
Certificate of Assessments, Payments, and Other Specified
Matters, for the taxable years 1983 and 1993 to 1995. Respondent
also asserted that petitioner's tax liabilities were not
discharged by the bankruptcy court.
This case was called for Hearing at the Court’s October 18,
2004, trial session in Phoenix, Arizona. At the start of the
hearing, petitioner filed a declaration in opposition to
respondent's motion, which stated in pertinent part that
petitioner was not permitted to make an audio recording of his
6 At the time the petition was filed, petitioner resided in
Tucson, Arizona.
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