- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011