Linda L. Pool - Page 6

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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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