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Collection Action(s) Under Section 6320 and/or 6330.1 The issue
for decision is whether respondent may proceed with collection by
levy of petitioner’s 2000 corporate income tax.
FINDINGS OF FACT
Some of the facts have been stipulated by the parties. The
stipulations, with accompanying exhibits, are incorporated herein
by this reference. At the time the petition was filed
petitioner’s principal place of business was located in Spokane,
Washington.
Petitioner is a professional corporation incorporated under
the state laws of Washington, and is wholly owned by Peter Dahlin
(Mr. Dahlin), an attorney. For taxable year 2000, petitioner
filed Form 1120-X, Amended U.S. Corporation Income Tax Return,
that reflected a tax liability of $1,463.
On December 9, 2004, respondent mailed to petitioner a Final
Notice Of Intent To Levy And Notice Of Your Right To A Hearing,
which included, inter alia, petitioner’s 2000 corporate Federal
income tax. Utilizing Form 12153, Request for a Collection Due
Process Hearing, petitioner timely requested a “CDP hearing face
to face with the hearing officer”, and stated its disagreement
with the assessment and levy of its corporate tax liability.
Petitioner also alleged mistakes in the computation of tax due
1Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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Last modified: November 10, 2007