- 5 - Petitioner did not pay the tax liability reported on his 1992 return. Based upon the liability reported on the return, which does not include interest, additions to tax, or penalties, petitioner and the revenue officer agreed to an installment payment schedule at the time the return was prepared. The terms of the installment agreement are unclear, but it appears that petitioner originally agreed to pay $100 per month toward his outstanding 1992 Federal income tax liability. We cannot tell with any degree of certainty when the installment payments began or ended, but as of the date of trial, petitioner had paid $2,514 towards his outstanding 1992 income tax liability. On September 8, 2000, respondent issued to petitioner a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 (the notice of lien). According to the notice of lien, petitioner’s then-outstanding liability for 1992 Federal income tax and related items totaled $10,132.48. Petitioner timely submitted Form 12153, Request for Collection Due Process Hearing. Petitioner stated in this request that he disagreed with the underlying liability because the liability in dispute was computed taking into account income that he neither earned nor received; namely, the income reported on the Form 1099 issued by State Farm. Petitioner’s administrative hearing was held on February 13, 2001. During the hearing, petitioner reiterated his challenge to the underlying liability. He did not raise anyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011