- 6 - On July 12, 2005, respondent issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 to petitioner regarding petitioner’s 1999, 2000, and 2003 tax years. In the notice of determination, respondent determined to sustain the proposed levy. On August 15, 2005, petitioner timely filed a petition regarding the notice of determination. At the time she filed her petition, petitioner lived in La Mesa, California. The petition contains frivolous and groundless arguments. On June 29, 2006, respondent sent petitioner a letter advising her of the provisions of section 6673 and that respondent would file a motion requesting sanctions under section 6673. On August 17, 2006, respondent filed a motion for summary judgment and to impose a penalty under section 6673. On August 21, 2006, the Court ordered petitioner to file any objection to respondent’s motion for summary judgment and to impose a penalty under section 6673 on or before September 5, 2006. Petitioner did not file any objection, and the Court calendared said motion for hearing at the Court’s San Diego, California, session on September 25, 2006. Petitioner appeared at the hearing, admitted receiving income for the years in issue, advanced frivolous and groundless arguments that the income was not subject to tax, and was warnedPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011