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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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Last modified: May 25, 2011