- 6 - administrative determination filed pursuant to section 6330 shall contain clear and concise assignments of each and every error which the petitioner alleges to have been committed in the levy determination and any issue not raised in the assignments of error shall be deemed to be conceded. Additionally, Rule 331(b)(5) states that such a petition shall contain clear and concise lettered statements of the facts on which the petitioner bases each assignment of error. In the petition, petitioner only makes the broad assertion that he does not have to pay taxes. There are neither specific assignments of error nor any statement of facts. Petitioner did not set forth in the petition any specific issues or factual basis for his disagreement with the tax liabilities reported on his 2001 return. Consequently, there is no genuine issue of material fact, and respondent is entitled to summary judgment with respect to the 2001 tax year. See Poindexter v. Commissioner, 122 T.C. 280 (2004), affd. 132 Fed. Appx. 919 (2d Cir. 2005).Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011