- 2 - can be granted and to impose a penalty under I.R.C. section 6673 (motion to dismiss).1 On June 13, 2005, petitioner filed a petition with the Court. By order dated June 21, 2005, the Court directed petitioner to file a proper amended petition on or before August 5, 2005. Petitioner filed the amended petition on August 4, 2005, based upon notices of determination concerning collection action(s) under section 6320 and/or 6330. In the amended petition, petitioner seeks redetermination of the deficiency and review of lien and levy actions for the 1997, 2000, and 2001 tax years. Petitioner also alleges that “Notice of administrative judgment by estoppel with sixty three (63) exhibits is evidenced”. On September 6, 2005, respondent’s motion to dismiss was filed. In his motion, respondent asserts that petitioner makes no factual claims of error and asserts only law and legal conclusions in the petition. Respondent further argues that petitioner’s claims are “nonsensical on their face.” On September 12, 2005, petitioner filed his objection to respondent’s motion to dismiss. On November 30, 2005, petitioner’s supplemental objection to respondent’s motion to dismiss was filed. 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011