- 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