- 2 - this opinion shall not be treated as precedent for any other case. This matter is before the Court on respondent’s motion for summary judgment pursuant to Rule 121. The issue we must decide is whether respondent’s Appeals Office abused its discretion in determining to proceed with collection of petitioner’s tax liabilities for taxable years 1998, 2000, 2001, and 2002 by lien. Background At the time of filing the petition, petitioner resided in Clarksdale, Mississippi. Petitioner filed an income tax return for taxable year 1998, but failed to pay all of the liability reported on the return. Petitioner failed to file income tax returns for 2000, 2001, and 2002. On October 27, 2003, respondent sent petitioner two letters requesting that petitioner file income tax returns for 2000 and 2001. On November 26, 2003, respondent received from petitioner returns for taxable years 2000 and 2001, which reported zeros on every line of the return. Attached to the returns for 2000 and 2001 were letters containing frivolous arguments. On February 27, 2004, respondent sent petitioner notices of deficiency for 2000 and 2001. On July 19, 2004, respondent assessed the tax liabilities, along with additions to tax andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007