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Respondent issued petitioner a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
(notice of determination) for unpaid Federal income tax for the
taxable year 1995. The notice of determination relates to a
notice of intent to levy dated September 11, 2004.
The issue for decision is whether, in the context of
respondent’s motion for summary judgment, respondent’s
determination to proceed with a notice of levy was an abuse of
discretion.
Background
Petitioner resided in Orlando, Florida, at the time the
petition was filed.
On February 12, 2002, respondent issued to petitioner a
notice of deficiency for the taxable year 1995. The notice
determined a $12,222 deficiency and a $1,872.50 addition to tax
pursuant to section 6651(a)(1). On May 31, 2002, the Court
received a petition submitted by Terrie Elaine Banks, to which
the Court assigned docket No. 9220-02S. The petition sought to
challenge the notice of deficiency for the taxable year 1995.
The petition arrived in an envelope bearing a private postage
meter postmark (Winter Garden, FL) dated May 13, 2002, and a U.S.
Postal Service postmark (Orlando, FL) dated May 14, 2002.
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Last modified: May 25, 2011