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Timothy J. Burke, for petitioner.
Nina P. Ching and John V. Cardone, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: This case is before the Court to review a
determination made by respondent’s Appeals Office that respondent
may proceed to collect by levy unpaid taxes with respect to
petitioner’s 2001 tax year. We review the determination pursuant
to section 6330(d)(1).
Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Petitioner resided in Kingston, Massachusetts, at the time
the petition was filed.
On November 1, 2002, respondent issued to petitioner a Final
Notice–Notice of Intent to Levy and Notice of Your Right to a
Hearing. The notice concerns petitioner’s unpaid Federal income
tax liability for 2001 of approximately $4,780 (the unpaid tax).
By letter dated November 15, 2002, petitioner’s attorney,
Timothy J. Burke, submitted to the Internal Revenue Service (IRS)
on petitioner’s behalf an IRS Form 12153, Request for a
Collection Due Process Hearing. On an attachment to the Form
12153, petitioner asserts: “It is in the best interest of the
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