Marvin Silverman - Page 3




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          request a letter containing frivolous and groundless arguments.             
          Petitioner did not propose any collection alternatives.                     
               On April 11, 2005, Appeals Account Resolution Specialist               
          Sophie Tittle sent petitioner a letter advising him that the                
          issues he raised were frivolous or were issues that the Appeals             
          Office does not consider.  Ms. Tittle scheduled a telephone                 
          conference for May 10, 2005.  Ms. Tittle reviewed petitioner’s              
          administrative file for 1989, 1990, and 1998 and confirmed that             
          respondent had complied with all applicable laws and                        
          administrative procedures.  On May 10, 2005, Settlement Officer             
          Lupe Silva called petitioner at the telephone number listed on              
          petitioner’s hearing request; however, the phone number no longer           
          was in service.                                                             
               Respondent issued petitioner a Notice of Determination                 
          Concerning Collection Action(s) Under Section 6320 and/or 6330              
          regarding his 1989, 1990, and 1998 tax years.  In the notice of             
          determination, respondent sustained the proposed collection                 
          action.                                                                     
                                     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           







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