Paul Thomas Demos - Page 9

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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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