Gerald H. Klawonn - Page 2




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          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.                                                                 










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