Carey K. Parker II - Page 4

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               On April 13, 2004, respondent issued to petitioner the                 
          decision letter.  The decision letter advised petitioner that               
          respondent reviewed the proposed collection action for 1994,                
          1995, 1996, and 1997 and that petitioner received an equivalent             
          hearing because he did not file a request for a section 6330                
          hearing within the time prescribed under section 6320 and/or 6330           
          in order to receive a section 6330 hearing.  The decision letter            
          further stated that petitioner did not raise any issues that were           
          relevant to paying his tax liability but that petitioner raised             
          only frivolous issues.  The decision letter also stated that                
          petitioner had no right to dispute the decision of the Appeals              
          officer in court, cited Pierson v. Commissioner, 115 T.C. 576               
          (2000), to petitioner, and warned petitioner that if he appealed            
          the decision letter to the Tax Court, the Court is empowered to             
          impose sanctions up to $25,000 for instituting or maintaining an            
          action primarily for delay or taking a position that is frivolous           
          or groundless.                                                              
               Petitioner petitioned the Court to dispute the decision                
          letter.  Respondent filed a motion to dismiss for lack of                   
          jurisdiction.  Petitioner filed a response to respondent’s motion           
          to dismiss for lack of jurisdiction.  Respondent filed a response           
          to petitioner’s response to respondent’s motion to dismiss for              
          lack of jurisdiction.                                                       







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