- 8 - proposed lien or levy is proper. Gerakios v. Commissioner, T.C. Memo. 2004-203; Chocallo v. Commissioner, T.C. Memo. 2004-152. We first consider whether the issues in this proceeding are moot. The notice of Federal tax lien filed for the 1995 tax year was released on May 18, 2001. The notice of Federal tax lien filed for the 1996, 1997, and 1998 tax years was released on December 5, 2003. Thus, as of December 30, 2003, the date the notice of determination was issued, all the tax liabilities were fully paid and all notices of Federal tax liens were released. The Court’s jurisdiction under section 6330 is generally limited to reviewing whether the proposed lien or levy is proper. Freije v. Commissioner, 125 T.C. 14 (2005). Since all the liens in this matter have, in fact, been released, we conclude that the matter is moot. See Greene-Thapedi v. Commissioner, 126 T.C. (2006); Gerakios v. Commissioner, supra; Chocallo v. Commissioner, supra. Having concluded that any issues regarding the filing of notices of Federal tax liens are moot, we do not consider any claim made by petitioner as to the underlying tax liabilities, and petitioner’s claim for abatement of interest and additions to tax. Greene-Thapedi v. Commissioner, supra. We note that petitioner claimed that respondent violated his due process rights. Petitioner did not cite or rely on any specific statute as a basis for this claim, and we generally havePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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