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opinion shall not be treated as a precedent for any other case.
This proceeding arises from a petition for review in
response to a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 that was sent to
petitioner on June 16, 2005, concerning his income tax liability
for 1997. The issue for decision is whether respondent abused
his discretion in sustaining a Federal tax lien with respect to
petitioner's 1997 liability.
Background
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts and the
exhibits attached thereto. At the time the petition was filed,
petitioner resided in Mobile, Alabama.
Petitioner filed a Federal income tax return for the 1997
taxable year.2 On that return, petitioner did not report any
income from Witness Incorporated (Witness) despite having
received a Form 1099-MISC, Miscellaneous Income, issued by
Witness that indicated he had received $56,370 in nonemployee
compensation during 1997. Petitioner was a cofounder and
2 The record does not include a copy of petitioner's 1997
return, and there is conflicting evidence in the record with
regard to petitioner's filing status for that year. As discussed
infra, the underlying liability for 1997 is not properly at issue
in this case. Consequently, petitioner's filing status for 1997
is not material.
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