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Notice of Determination Concerning Collection Actions Under
Section 6320 and/or 6330. Thereafter, petitioner filed a timely
petition with this Court on December 22, 2004.1
In the petition, petitioner alleges that he is not obligated
to pay Federal income taxes, stating:
After reading the tax code I determined that I was not
obligated to pay Federal Income tax. I filed EXEMPT W-
4 Form with my employer and sent paper work to the IRS
stating my position through certified mail. I asked
the IRS to get back to me within 30 days. I did not
hear anything from the IRS until 6 YEARS later.
Interest + penalties accured. The IRS was negligent.
Thus, it appears that petitioner is attempting to challenge the
underlying tax liabilities for the 1998, 1999, 2000, and 2001 tax
years.
Discussion
The purpose of summary judgment is to expedite litigation
and avoid the expense of unnecessary trials. Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). A motion for summary
judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121(a) and (b). The moving party bears the burden of
proving that there is no genuine issue of material fact, and
factual inferences are viewed in a light most favorable to the
nonmoving party. Craig v. Commissioner, 119 T.C. 252, 260
1In his petition, petitioner incorrectly selected the box on
the Court’s standard petition form for “Petition for
Redetermination of a Deficiency”. The Court has treated the
petition as a “Petition for Lien or Levy Action”.
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Last modified: May 25, 2011