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Revenue Code, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
This proceeding arises from a petition for judicial review
filed in response to a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 (notice of
determination) issued to petitioner in June 2005 and supplemented
in October 2006. Pursuant to section 6330(d), petitioner seeks
review of respondent’s determination sustaining a proposed levy
for the taxable years 1997, 1998, and 1999.
After concessions,1 the issues for decision are: (1)
Whether respondent correctly determined petitioner’s underlying
tax liability for the years at issue; and (2) whether respondent
abused his discretion by sustaining the proposed levy. The
parties filed cross-motions for summary judgment pursuant to Rule
121(a). For the reasons discussed below, we shall grant
respondent’s motion and deny petitioner’s motion.
Background
Petitioner resided in Whittier, California, when the
petition was filed.
During the years at issue, petitioner worked for Viking
Freight, Inc. (Viking Freight), which was later acquired by
FedEx. Petitioner filed a Federal income tax return for 1997.
1 Respondent concedes unreported income of $13 and $14 for
1997 and 1999, respectively, and an addition to tax under sec.
6651(a)(2) for 1997.
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