Opinion
10917-21L
08-23-2022
RENEE ALBRIGHT VENDEMIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Richard T. Morrison Judge
On August 10, 2021, petitioner filed an amended petition disputing respondent's notice of determination concerning collection action(s) under section 6320 and/or 6330, dated March 18, 2021. The notice of determination sustained respondent's filing of a notice of intent to levy with respect to petitioner's outstanding joint income tax liability for the taxable year 2016.
On April 6, 2022, respondent filed a motion for summary judgment, together with a declaration.
On April 8, 2022, the Court ordered petitioner to file a response to respondent's motion for summary judgment by May 9, 2022. The Order explained that failure to comply therewith may result in the granting of respondent's motion and entry of decision in respondent's favor.
On May 23, 2022, the Court extended the deadline to June 23, 2022, for petitioner to file a response to respondent's motion for summary judgment.
As of the date of this Order and Decision, no response to respondent's motion for summary judgment has been received from or on behalf of petitioner. Petitioner did not respond to Appeals' proposal of an installment agreement, did not submit the collection-information form required by Appeals for it to consider a better proposal, and did not participate in the conference scheduled by Appeals. Although the amended petition purports to raise questions about petitioner's underlying tax liability, petitioner did not present these views to Appeals.
Upon due consideration, it is
ORDERED that respondent's April 6, 2022 motion for summary judgment filed May 24, 2011, is granted. It is further
ORDERED AND DECIDED that respondent may proceed with the proposed collection action (levy) for the taxable year 2016, as determined by respondent's Office of Appeals in its notice of determination dated March 18, 2021, upon which notice this case is based.