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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 warned
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Last modified: May 25, 2011