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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 have
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