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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
the petition, petitioners resided in Arcadia, Michigan.
In 1992, respondent issued statutory notices of deficiency
to petitioners for 1987, 1988, and 1989. In 1993, respondent
issued a statutory notice of deficiency to petitioners for 1991.
Petitioners filed petitions with the Court regarding their 1987,
1988, 1989, and 1991 tax years.
The Court issued Muldavin v. Commissioner, T.C. Memo. 1997-
531,2 orders, and decisions which addressed the deficiencies and
additions to tax for petitioners’ 1987, 1988, and 1989 tax years.
Petitioners did not appeal these decisions. A stipulated
decision was entered for petitioners’ 1991 tax year.
On August 2, 1999, respondent prepared a Notice of Federal
Tax Lien (FTL notice) for Roger Muldavin (Mr. Muldavin) for 1987
and an FTL notice for petitioners for 1988, 1989, and 1991. That
same day, respondent mailed the FTL notices to the Register of
Deeds, Manistee County, Michigan (register’s office).
On August 5, 1999, respondent issued a Notice of Federal Tax
Lien Filing and Your Right to a Hearing Under I.R.C. 6320
2 This opinion also addressed the deficiencies and
additions to tax determined by respondent for petitioners’ 1985
and 1986 tax years.
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