Mardi Rustam - Page 2

                                        - 2 -                                         
          Revenue Code, as amended, and all Rule references are to the Tax            
          Court Rules of Practice and Procedure.                                      
               At the time of filing his petition, petitioner resided in              
          Toluca Lake, California.                                                    
               On January 21, 2004, respondent’s Appeals Office issued a              
          Notice of Determination Concerning Collection Action(s) Under               
          Section 6320 and/or 6330, determining that a proposed levy to               
          recover a section 6672 trust fund penalty liability with respect            
          to petitioner’s 1997 tax year was appropriate.2  The first page             
          of the notice of determination stated:                                      
               If you want to dispute this determination in court, you                
               must file a petition with the United States Tax Court                  
               for a redetermination within 30 days from the date of                  
               this letter.                                                           
                    *     *     *     *     *     *     *                             
               The time limit for filing your petition is fixed by                    
               law.  The courts cannot consider your case if you file                 
               late.  If the court determines that you made your                      

               2SEC. 6672.  FAILURE TO COLLECT AND PAY OVER TAX, OR                   
                         ATTEMPT TO EVADE OR DEFEAT TAX.                              
                    (a) General Rule.-- Any person required to collect,               
               truthfully account for, and pay over any tax imposed by this           
               title who willfully fails to collect such tax, or truthfully           
               account for and pay over such tax, or willfully attempts in            
               any manner to evade or defeat any such tax or the payment              
               thereof, shall, in addition to other penalties provided by             
               law, be liable to a penalty equal to the total amount of the           
               tax evaded, or not collected, or not accounted for and paid            
               over.  No penalty shall be imposed under section 6653 or               
               part II of subchapter A of chapter 68 for any offense to               
               which this section is applicable.                                      

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011