- 2 - 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 subsequentlyPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011