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determination) for unpaid Federal income tax liabilities of
petitioner for 1990 through 1993. In response to that notice and
pursuant to sections 6320 and 6330(d), petitioner timely
petitioned this Court to review the determination to proceed with
collection by filing a nominee Notice of Federal Tax Lien (NFTL).
The issue for decision is whether the Appeals Office abused
its discretion in upholding respondent’s filing of a nominee NFTL
in this case.
FINDINGS OF FACT
Background
Petitioner resided in Claremore, Oklahoma, when he filed his
petition in this case.
From 1975 to 1996, approximately, excluding the periods of
time that he was incarcerated, petitioner derived at least some
portion of his income from cheating at gambling. By his own
estimate, since 1975, petitioner has earned substantial income by
cheating at gambling.
At various times during the 1980s through the mid-1990s,
petitioner was prosecuted in Nevada, New Jersey, and Oklahoma for
money laundering, structuring monetary transactions, felony theft
by deception, possession of slot machine cheating devices, fraud,
and burglary, and he served time in prison. In connection with
the Nevada prosecution, petitioner was arrested in Tulsa,
Oklahoma, on May 13, 1987. Petitioner had at least $30,000 in
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