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determination to collect amounts by jeopardy levy relating to
petitioner’s 1987-89 tax years. The sole issue remaining for
decision is whether respondent’s determination was an abuse of
discretion. We hold that it was not.
Section references are to the Internal Revenue Code as
amended.
Background
A. Petitioner
Petitioner resided in Naples, Florida, when he filed his
petition. He was retired at the time of trial. Before he
retired, petitioner and his brothers operated Dorn Paint &
Hardware Co, Inc., in Madison, Wisconsin.
Petitioner’s former wife filed for divorce in the Circuit
Court of Dane County, Wisconsin, in 1984. As a result of his
divorce in 1987, petitioner was ordered to transfer amounts from
his IRA, pension plan, and profit sharing accounts to his former
wife.
B. Petitioner’s Nonfiling of Income Tax Returns and Notice of
Deficiency
Petitioner did not file income tax returns for tax years
1987-89. Respondent issued a notice of deficiency to petitioner2
for those years, in which respondent determined, inter alia, that
2 The parties dispute whether petitioner received the notice
of deficiency for 1987-89. For reasons discussed in the opinion
below, we need not decide that issue.
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