- 2 - Federal income tax liability for 1999. We review the determination pursuant to section 6330(d)(1).1 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and as applicable to this case, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background This case was submitted for decision without trial pursuant to Rule 122. Facts stipulated by the parties are so found. The stipulation of facts filed by the parties, with attached exhibits (the stipulation of facts), is included herein by this reference. In their joint motion asking leave to submit this case under Rule 122, the parties agreed that the case may be submitted on the basis of the pleadings and the stipulated facts. By the petition, petitioner assigns error to the determination as follows: “I believe the determination is incorrect and have already provided written evidence including from third parties which contradicts key factual statements in the IRS’s determination. This evidence has been ignored by the IRS.” Attached to the petition is a copy of a two-page document entitled “Notice of Determination Concerning Collection Action(s) 1 While petitioner checked the box on the petition indicating that he is seeking a redetermination of a deficiency, clearly this action concerns a collection action, and we shall treat it as such.Page: Previous 1 2 3 4 5 NextLast modified: March 27, 2008