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motion for leave and in his motion to permit levy, respondent
alleges that petitioner’s underlying tax liabilities are not at
issue and that release of the levied funds would be highly
prejudicial to respondent. In support of his position,
respondent alleges that petitioner was offered an opportunity for
a hearing before an Appeals officer but failed to take such
opportunity and instead responded with letters asserting
frivolous arguments. Respondent alleges that petitioner is
merely attempting to delay collection of his liabilities.
Respondent attached copies of the notice of deficiency with
regard to petitioner’s tax year 1999 that indicate it was sent to
petitioner on December 18, 2002. The notice of deficiency
determined an increase in tax of $1,421,128, a section 6654
failure to pay estimated income tax penalty of $68,447.66 and a
section 6651 failure to file or to pay tax penalty of
$353,433.83. Respondent states that petitioner did not file a
petition for redetermination of the proposed deficiency with the
Tax Court.
In two separate orders dated August 29, 2006, the Court
directed petitioner to reply on or before September 13, 2006, to
respondent’s objection to petitioner’s motion for leave and to
5(...continued)
In the motion to permit levy, respondent states that he has
since released outstanding wage levies, and has advised Midwest
Bank NA-Data Center and Ameritrade Inc. not to remit the levied
funds at this time.
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Last modified: May 25, 2011