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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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