- 2 -
proceed with collection of petitioner’s tax liabilities was not
an abuse of discretion. For reasons stated below, we grant
respondent’s motion.
Except as otherwise noted, section references are to the
Internal Revenue Code as amended, and Rule references are to the
Tax Court Rules of Practice and Procedure.
Background
Petitioner resided in Brevard, North Carolina, when he filed
his petition.
A. The Lien and Levy Proceeding
On March 13, 2000, respondent issued to petitioner a Notice
of Federal Tax Lien Filing and Notice of Your Right to a Hearing
relating to the filing of a lien in Ohio. On June 27, 2000,
respondent issued to petitioner a Notice of Federal Tax Lien
Filing and Notice of Your Right to a Hearing relating to the
filing of a lien in North Carolina. Petitioner timely requested
a hearing under section 6320(b).
On January 5, 2001, respondent sent petitioner Individual
Master File transcripts for tax years 1986, 1988, 1989, 1995,
1996, and 1998, which identified petitioner, the type of tax, the
tax period, the dates of assessment, and the amounts of
assessment.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011