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Forms 4340, Certificate of Assessments, Payments, and Other
Specified Matters, for the years at issue. The settlement
officer requested that petitioner submit, inter alia, tax returns
for 2004 and 2005 and a Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals.
Although the parties exchanged correspondence over the next
few months, petitioner did not provide the requested information.
Respondent issued petitioner a Supplemental Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (supplemental notice) on October 2, 2006. The
supplemental notice sustains the proposed levy and states that
applicable legal and administrative requirements were met.
In February 2007, the parties filed cross-motions for
summary judgment.5 Respondent and petitioner each filed an
objection, and petitioner filed a reply to the objection.
Discussion
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). Summary judgment may be
granted with respect to all or any part of the legal issues in
controversy “if the pleadings, answers to interrogatories,
depositions, admissions, and any other acceptable materials,
5 Respondent had filed an earlier motion for summary
judgment on Apr. 11, 2006, which we denied without prejudice.
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Last modified: November 10, 2007