Thomas C. Johnson - Page 3

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          During the period surrounding his marital separation and the                
          onset of his illness, petitioner found it difficult to cope with            
          his financial affairs.  He did not file Federal income tax                  
          returns for 1997 or 1998.  Petitioner then filed his 1999 return,           
          which was posted at the Internal Revenue Service Center on May              
          29, 2000.  The return reported a tax liability that was not fully           
          paid either by withholdings or by any payment submitted with the            
          return.  Respondent made no adjustments to petitioner’s 1999                
          reporting and accepted the return as filed.                                 
               Following assessments of petitioner’s tax liabilities for              
          1995, 1996, and 1999, respondent on or about September 5, 2000,             
          filed a notice of Federal tax lien with the Judge of Probate in             
          Mobile County, Alabama.  The notice of lien reflected a total               
          unpaid balance of $7,235.61, comprising $1,726.20 for 1995,                 
          $4,361.32 for 1996, and $1,148.09 for 1999.  Then, on September             
          8, 2000, respondent issued to petitioner a Notice of Federal Tax            
          Lien Filing and Your Right to a Hearing Under IRC 6320 regarding            
          the just-described lien.                                                    
               Respondent on October 10, 2000, received from petitioner a             
          Form 12153, Request for a Collection Due Process Hearing, with              
          the following explanation of his disagreement with the lien:                
          “12-31-95 and 12-31-96 is [sic] not correct.  Would like to                 
          explain at the hearing or over the phone”.  Appeals Officer                 








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