Edward Kazuo Ozaki - Page 2

                                         -2-                                          
          Federal income taxes that respondent considers to be owed by                
          petitioner for 1994 through 2000.  Following a trial on the                 
          propriety of the lien, we sustain the determination of Appeals.             
                                  FINDINGS OF FACT                                    
               Most facts were stipulated.  We find the facts accordingly.            
          When the petition was filed herein, petitioner resided in                   
          Chicago, Illinois.                                                          
               Petitioner received notices of deficiency for 1994 through             
          2000, and he petitioned this Court with respect thereto.  On                
          July 16, 2003, the Court sustained respondent’s determinations in           
          the notices of deficiency, as modified by respondent’s                      
          concession.  See Ozaki v. Commissioner, T.C. Memo. 2003-213.                
          Respondent assessed the resulting amounts and mailed to                     
          petitioner a notice and demand for payment of those amounts.                
               On January 12, 2005, respondent mailed to petitioner a                 
          notice advising petitioner that respondent had filed a Notice of            
          Federal Tax Lien for the subject years and that petitioner had as           
          to this filing a right under section 6320 to a hearing with                 
          Appeals.  Petitioner requested that hearing on February 4, 2005.            
          The request essentially alleged that petitioner had a mental                
          condition and had suffered racial injustice that entitled him to            
          relief from the lien.  On October 18, 2005, Appeals held a                  


               1(...continued)                                                        
          applicable versions of the Internal Revenue Code.                           




Page:  Previous  1  2  3  4  Next

Last modified: May 25, 2011