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response to a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 issued for unpaid
Federal income tax liabilities for taxable years 1994 and 2002.2
The sole issue for decision is whether respondent abused his
discretion in sustaining a Notice of Federal Tax Lien. For the
following reasons, we hold that there was no abuse of discretion
in this case.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
Petitioners resided in Egg Harbor City, New Jersey, on the
date the petition was filed.
Prior Assessments and Offer-in-Compromise
Respondent assessed a Federal income tax liability of
$28,222.27 against petitioners for taxable year 1993 on August 7,
1995. Respondent also assessed a Federal income tax liability of
$19,934.61 against petitioners for taxable year 1994 on July 31,
1995. The total amount assessed for petitioners’ 1993 and 1994
Federal income tax liabilities was $48,156.88.
Petitioners made an Offer-in-Compromise (OIC) for the
Federal income tax liabilities assessed for the 1993 and 1994
2Petitioners’ liability for the taxable year 2002 has been
satisfied and is no longer in issue.
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