- 2 - The petition was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6330 (notice of determination). Pursuant to section 6330(d), petitioners seek review of respondent’s notice of intent to levy relating to their tax liabilities for 1992, 1993, and 1996.1 Background The stipulation of facts and the exhibits received into evidence are incorporated herein by reference. At the time the petition was filed, petitioners resided in Lynnwood, Washington. Petitioners jointly filed for 1992, 1993, and 1996 Forms 1040, U.S. Individual Income Tax Return. Because petitioners self-assessed their taxes for all years in issue, no statutory notice of deficiency was issued. During the years at issue, petitioner Richard Balser (Mr. Balser) and petitioner Corinne Balser (Mrs. Balser) were the sole owners of Homewood Development, Inc. (HDI). HDI was in the business of developing residential projects. 1Petitioners also sought the review of a Notice of Determination Concerning Collection Action(s) Under Section 6330 issued to Mr. Balser regarding a civil penalty under sec. 6672 for the third quarter of 1996. The Court’s jurisdiction to review the Commissioner’s determination regarding a collection matter is limited to cases where the underlying tax liability is of the type over which the Court normally has jurisdiction. See Moore v. Commissioner, 114 T.C. 171, 175 (2000). By order dated Jan. 25, 2006, the Court granted respondent’s motion to dismiss for lack of jurisdiction to the extent that petitioners seek a review of the collection activity regarding the sec. 6672 penalty.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007