- 7 - by the Court that her arguments were frivolous and groundless and the Court could impose a penalty pursuant to section 6673. Petitioner, however, disregarded these warnings and continued to advance frivolous and groundless arguments. Discussion I. Motion for Summary Judgment Rule 121(a) provides that either party may move for summary judgment upon all or any part of the legal issues in controversy. Full or partial summary judgment may be granted only if it is demonstrated that no genuine issue exists as to any 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 is no genuine issue as to any material fact and that a decision may be rendered as a matter of law. II. Determination To Proceed With Collection Section 6330(a) provides that the Secretary shall furnish taxpayers with written notice of their right to a hearing before any property is levied upon. Section 6330 further provides that the taxpayer may request administrative review of the matter (in the form of a hearing) within a prescribed 30-day period. Sec. 6330(a) and (b).Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011