- 2 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011