Scott William Katz - Page 4




                                        - 4 -                                         
          Commissioner regarding his “1990 income tax liability.”  On March           
          10, 1998, the bankruptcy court denied the request, ruling that              
          petitioner’s “1990 tax liabilities were not discharged in * * *             
          [the] bankruptcy case.”  In re Katz, No. 90-39248-BKC-RAM (Bankr.           
          S.D. Fla., Mar. 10, 1998).  On May 14, 1998, with regard to the             
          original tax dispute, we entered a decision stipulated by the               
          parties setting out the amounts of the tax deficiency and                   
          additions to tax and providing for statutory interest.4  See Katz           
          v. Commissioner, Docket No. 21359-96 (May 14, 1998).  The amounts           
          of the tax deficiency and additions to tax redetermined in the              
          decision were much lower than the amounts set forth in the notice           
          of deficiency.  Subsequently, respondent assessed the tax                   
          deficiency, additions to tax, and interest.                                 
               On February 23, 1999, respondent filed a Notice of Federal             
          Tax Lien (lien filing) with regard to the amounts assessed for              
          the 1990 tax year in the county recorder’s office for Palm Beach            
          County, Florida.  On February 27, 1999, respondent transmitted to           
          petitioner a “Notice of Federal Tax Lien Filing and Your Right to           
          a Hearing under IRC 6320”.  On or about March 31, 1999, pursuant            
          to section 6320(b), petitioner requested an Appeals hearing from            
          respondent’s Appeals Office.  In his request, petitioner                    
          contested the entire amount listed in the lien filing.                      


               4  The decision provided:  “It is further stipulated that              
          interest will be assessed as provided by law on the deficiency              
          and additions to tax due from the petitioner.”                              





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011