Cynthia Ann Schlosser - Page 6

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          or denials of the pleadings but must set forth specific facts               
          showing that there is a genuine issue for trial.  Rule 121(d).              
               Section 6330(a) provides that no levy may be made on any               
          property or right to property of any person unless the Secretary            
          first notifies him or her in writing of the right to a hearing              
          before the Appeals Office.2  At the hearing, a taxpayer may raise           
          any relevant issues including appropriate spousal defenses,                 
          challenges to the appropriateness of collection actions, and                
          offers of collection alternatives.  Sec. 6330(c)(2)(A).  Under              
          certain circumstances, the taxpayer may also challenge the                  
          existence or amount of the underlying tax liability.  Sec.                  
               In Lunsford v. Commissioner, 117 T.C. 183, 185-186 (2001),             
          we stated:                                                                  
                    Our Rules require petitioners to specify the facts                
               upon which they rely for relief under section 6330.  A                 
               petition filed under section 6330 must contain “Clear                  
               and concise lettered statements of the facts on which                  
               the petitioner bases each assignment of error”.  Rule                  
               331(b)(5).  * * *                                                      
               In the petition and the response to respondent’s motion for            
          summary judgment, petitioner has advanced nothing but frivolous             
          and meritless arguments with respect to her underlying tax                  
          liability for 1994.  We shall not painstakingly address                     
          petitioner’s assertions “with somber reasoning and copious                  

               2 Similar hearing rights are provided to contest the filing            
          of a Federal tax lien under sec. 6320.                                      

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