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On March 18, 2005, petitioner filed an amended petition and
checked the box for “Petition for Redetermination of a
Deficiency”.7 Paragraph 4 of the petition states:
No collection due process hearing was held before the
determination was issued. Under IRC 6320, 6330 I have
the right to a fair hearing, and was denied the right
to the hearing.
Respondent’s Motion For Summary Judgment
On August 12, 2005, respondent filed a Motion For Summary
Judgment, together with a Declaration from the Appeals officer
with attached exhibits.
By Order dated August 15, 2005, the Court directed
petitioner to file an objection or other response to respondent’s
motion on or before September 12, 2005.
On September 8, 2005, petitioner filed a motion for an
extension of time to respond to respondent’s motion. By Order
dated September 8, 2005, the Court granted petitioner’s motion
and extended the time within which petitioner was to respond to
respondent’s motion to September 30, 2005.
Petitioner did not file a response within the period
specified in the Court’s September 8, 2005 Order.
7 The Court has treated this pleading as a Petition for
Lien or Levy Action (Collection Action).
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Last modified: May 25, 2011