Cheryl Ward - Page 3

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               This case is before the Court on respondent’s motion for               
          summary judgment under Rule 121.  This proceeding arises from a             
          petition for judicial review filed in response to a Notice of               
          Determination Concerning Collection Action(s) Under Section 6320            
          sent to petitioner.                                                         
                                     Background                                       
               At the time the petition in this case was filed, petitioner            
          resided in Oakland, California.                                             
               Petitioner filed for 1999 and 2000, Forms 1040, U.S.                   
          Individual Income Tax Return, on February 21, 2001, and on May              
          14, 2001, respectively.  Petitioner failed to pay all of the                
          taxes reported on the returns.  The unpaid taxes, related                   
          penalties, and interest were accordingly assessed.  Respondent              
          did not issue to petitioner a statutory notice of deficiency for            
          1999 or 2000.                                                               
               Respondent subsequently filed a Notice of Federal Tax Lien             
          (tax lien) with respect to petitioner’s tax liabilities for 1999            
          and 2000.  On July 20, 2004, respondent issued to petitioner a              
          Notice of Federal Tax Lien Filing and Your Right to a Hearing               
          Under IRC 6320.  Petitioner timely submitted a Form 12153,                  
          Request for a Collection Due Process Hearing.                               
               On the Form 12153, petitioner stated in the explanation that           
          she did not agree with the tax lien because “I am applying for an           
          offer in compromise.  I am disabled.”  Petitioner subsequently              






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