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Practice and Procedure, and all section references are to the
Internal Revenue Code, as amended.
This matter is before us under Rule 121 on the parties’
cross-motions for summary judgment.
Respondent issued a notice of determination concerning
collection action(s) under section 6320 and/or 6330 sustaining a
levy on petitioner’s property to collect unpaid taxes for taxable
years 2000, 2001, and 2002. The underlying issue for decision in
this matter is whether respondent’s Appeals Office abused its
discretion by rejecting offers-in-compromise made on petitioner’s
behalf, thus sustaining respondent’s proposed levy action against
petitioner’s Individual Retirement Account (IRA).
Background
For purposes of addressing the parties’ cross-motions for
summary judgment, the record in this matter consists of the
pleadings, the parties’ cross-motions for summary judgment, and
the relevant documents attached thereto. The underlying facts in
this case are not in dispute.
In order to collect unpaid Federal income taxes and related
additions to tax and interest for 2000, 2001, and 2002 respondent
seeks to levy on petitioner’s IRA for the taxes owed as follows:
$1,636.51 for 2000; $27,368.92 for 2001; and $5,800.83 for 2002.
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Last modified: March 27, 2008