- 11 - 05L did not seek to challenge the underlying income tax liabilities that respondent was seeking to collect. Respondent moved to dismiss for lack of jurisdiction as to Mr. Salazar’s employment tax liabilities on the grounds that respondent had never issued a notice of determination concerning a collection action under section 6330 with respect to the employment tax liabilities. In a Salazar v. Commissioner, T.C. Memo. 2006-7, filed January 18, 2006, we found that no notice of determination for purposes of section 6330 had been issued with respect to petitioners’ employment tax liabilities and granted respondent’s motion to dismiss for lack of jurisdiction with respect to Mr. Salazar’s employment tax liabilities.3 In the interim, on June 20, 2005, the bankruptcy trustee submitted to the bankruptcy court a Trustee’s Final Report and Application for Compensation and Reimbursement (the final report). In the final report, payment on respondent’s secured claim of $19,915.40 was not allowed. Instead, payment on respondent’s priority claim of $43,673.45 was allowed. On August 22, 2005, the bankruptcy trustee disbursed $17,834.51 to respondent. 3Respondent also moved to dismiss on the grounds that the Court lacked jurisdiction to hear any challenge to Mr. Salazar’s employment tax liabilities. However, because respondent issued a notice of determination with respect to Mr. Salazar’s employment tax liabilities on Oct. 18, 2006, respondent admits that we now have jurisdiction to review his determination under sec. 6330(d)(1). See Callahan v. Commissioner, 130 T.C. __ (2008).Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: March 27, 2008