- 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
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