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requested tax returns or submit a current financial statement to
the Appeals officer by the January 31, 2007, deadline.
On February 15, 2007, the Appeals officer issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 sustaining the proposed levy.
On March 14, 2007, petitioner timely filed its petition.
Petitioner argues that there is no proposed deficiency as set
forth in the notice of determination. Petitioner further alleges
that the Appeals officer’s determination was erroneous because it
contravened the applicable Code provisions, rules, and
regulations. However, petitioner states that the basis of its
allegations “cannot be fully set forth at this time given the
unclear basis for the Commissioner’s conclusions.” Lastly,
petitioner contends it was improperly denied the right to an in-
person section 6330 hearing.
On October 4, 2007, we issued petitioner a notice setting
its case for trial during the Court’s March 10, 2008, Chicago,
Illinois, trial session. On November 21, 2007, respondent filed
his motion for summary judgment. On December 7, 2007, Mr.
Statland submitted a motion to withdraw as petitioner’s
representative, citing petitioner’s refusal to cooperate and
failure to respond to his repeated communication attempts. Mr.
Statland also submitted a motion requesting additional time for
petitioner to obtain new counsel and/or respond to respondent’s
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