- 27 - Appeals has determined that filing of the Notice of Federal Tax Lien was appropriate in your case, consid- ering that you were not able to offer other means to protect the government’s interest in your assets. Therefore, lien filing is considered to be the most efficient method to facilitate collection of the tax. [Reproduced literally.] The notice of determination made no determination with respect to the notice of intent to levy issued with respect to petitioner’s taxable year 2001. See supra note 3. In petitioner’s amended petition, petitioner alleged: “I would like to work out a payment plan. I cannot raise enough capital to cover the entire amount. I have worked with you and need a reasonable settle- ment!” Discussion The Court may grant summary judgment where there is no genuine issue of material fact and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). We conclude that there are no genuine issues of material fact regarding the questions raised in respondent’s motion. Petitioner does not dispute the existence or the amount of petitioner’s unpaid 2001 income tax liability or petitioner’s unpaid 2002 income tax liability in the pleadings that he filed in this case or in his response to respondent’s motion. Although not altogether clear, petitioner appears to argue that respondent abused respondent’s discretion in determining in the notice ofPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 NextLast modified: November 10, 2007