W. James Kubon - Page 4

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               Collection System and Appeals attempted to solicit Mr.                 
               Kubon’s cooperation in proposing an alternative to enforced            
               collection actions.  Mr. Kubon has not voluntarily filed               
               income tax returns for 2000, 2001 or 2002.  Mr. Kubon failed           
               to provide any financial information, and did not propose an           
               acceptable collection alternative.  The Internal Revenue               
               Service may proceed with enforced collection actions.                  
          On January 30, 2004, petitioner filed with the Court a Petition             
          for Lien or Levy Action Under Code Section 6320(c) or 6330(d), in           
          which petitioner disputes the notice of determination because he            
          was allegedly denied a section 6330 hearing.                                
               On September 1, 2004, respondent filed a Motion for Summary            
          Judgment and To Impose Penalty Under Section 6673, in which                 
          respondent moves for summary adjudication in respondent’s favor             
          in this case for all of the legal issues in controversy and                 
          requests that the Court impose a penalty pursuant to section 6673           
          because petitioner instituted these proceedings solely for the              
          purpose of delay and advanced only frivolous arguments.                     
          Accompanying the motion for summary judgment, respondent filed a            
          declaration of Settlement Officer Colleen Cahill (Ms. Cahill),              
          which states that she reviewed petitioner’s TXMODA transcript for           
          1999 as part of her verification that all legal and                         
          administrative requirements for levy had been met.  Respondent              
          attached to Ms. Cahill’s declaration the TXMODA transcript that             
          Ms. Cahill reviewed and the Form 4340, Certificate of                       
          Assessments, Payments, and Other Specified Matters, for                     







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