- 6 - and/or 6330, determining that the proposed levy action was appropriate. Petitioner timely filed a Petition for Lien or Levy Action with this Court. The petition set forth the following allegations: 1) Paying income tax No legal law statute/code available for findings 2) frivolous filings & penalties not valid 3) Assessment cannot be made by IRS/self assessment only 4) IRS Tax hearing determination/6320/6330 –- 5) Numerous issues pertaining to invalid procedures/findings based on NO LAW to collect taxes. Unconstitutional. On September 25, 2003, respondent filed a Motion to Dismiss for Lack of Jurisdiction and to Strike as to I.R.C. � 6702 Penalty for Tax Year 1996 on the ground that this Court lacks jurisdiction over the section 6702 penalty. Petitioner did not object, and we granted respondent’s motion to dismiss with respect to any portion of the case purporting to be an appeal of the section 6702 penalty and ordered that references to the section 6702 penalty in the petition be stricken. Respondent filed a Motion for Summary Judgment on December 17, 2004. Discussion The purpose of summary judgment is to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011