- 3 -
about December 19, 2003, petitioner timely filed a Form 12153,
Request for a Collection Due Process Hearing, in which petitioner
recited statements, contentions, arguments, and requests that the
Court finds to be frivolous and/or groundless. On May 6, 2004, a
hearing was held. Petitioner did not propose any collection
alternatives at the hearing.
On June 2, 2004, respondent issued a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330 to
petitioner regarding his 1999 and 2000 tax years (notice of
determination). In the notice of determination, respondent
determined that the proposed collection action was appropriate
and to proceed with collection.
On July 6, 2004, petitioner timely filed a petition for lien
or levy action under Code section 6320(c) or 6330(d) seeking
review of respondent’s determination to proceed with collection
of petitioner’s 1999 and 2000 tax liabilities.2 Except for an
argument under section 7521(a)(1), the petition contains
statements, contentions, arguments, and questions that the Court
2 Attached to the petition are copies of a notice of
determination regarding respondent’s levy action for petitioner’s
unpaid tax liabilities for the 1999 and 2000 tax years, and a
Decision Letter Concerning Equivalent Hearing Under Sec. 6320
and/or 6330 regarding respondent’s lien action for petitioner’s
unpaid liabilities for the 1999 and 2000 tax years. In an order
dated Jan. 5, 2005, this Court granted respondent’s motion to
dismiss for lack of jurisdiction with respect to sec. 6320 for
the taxable years 1999 and 2000 on the ground that no notice of
determination was issued regarding respondent’s lien action
because petitioner failed to file a timely request for an Appeals
Office hearing.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011