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the levy to collect 1996 Federal income taxes of approximately
$135,024.03.1
We sustain respondent’s filing of the notice of lien and
respondent’s determination as to the proposed levy. Unless
otherwise noted, section references are to the applicable
versions of the Internal Revenue Code. Rule references are to
the Tax Court Rules of Practice and Procedure.
Background
Petitioners filed a joint 1996 Federal income tax return on
October 20, 1997. Respondent assessed the Federal income tax
liability shown on that return on November 24, 1997.
On July 25, 2000, respondent sent to petitioners a notice of
deficiency for 1996. The notice of deficiency determined that
petitioners were liable for a deficiency of $83,521 and an
accuracy-related penalty of $16,704.20 under section 6662(a).
Petitioners did not petition this Court with respect to the
notice of deficiency. On December 18, 2000, respondent assessed
the amount of the deficiency and accuracy-related penalty shown
in the notice of deficiency.
On April 12, 2001, respondent mailed to each petitioner an
identical letter, Final Notice - Notice of Intent to Levy and
Notice of Your Right to a Hearing (final levy notice). The final
1 We use the term “approximately” because these amounts were
computed before the present proceeding and have since increased
on account of interest.
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