Jason Harrington - Page 3




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          this opinion shall not be treated as precedent for any other                
          case.                                                                       
               This matter is before the Court on respondent’s motion for             
          summary judgment pursuant to Rule 121.  The issue we must decide            
          is whether respondent’s Appeals Office abused its discretion in             
          determining to proceed with collection of petitioner’s tax                  
          liabilities for taxable years 1998, 2000, 2001, and 2002 by lien.           
                                     Background                                       
               At the time of filing the petition, petitioner resided in              
          Clarksdale, Mississippi.                                                    
               Petitioner filed an income tax return for taxable year 1998,           
          but failed to pay all of the liability reported on the return.              
          Petitioner failed to file income tax returns for 2000, 2001, and            
          2002.  On October 27, 2003, respondent sent petitioner two                  
          letters requesting that petitioner file income tax returns for              
          2000 and 2001.  On November 26, 2003, respondent received from              
          petitioner returns for taxable years 2000 and 2001, which                   
          reported zeros on every line of the return.  Attached to the                
          returns for 2000 and 2001 were letters containing frivolous                 
          arguments.                                                                  
               On February 27, 2004, respondent sent petitioner notices of            
          deficiency for 2000 and 2001.  On July 19, 2004, respondent                 
          assessed the tax liabilities, along with additions to tax and               








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