Michael A. and Esther N. Milnes - Page 2




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               Section references are to the Internal Revenue Code as                 
          amended, and Rule references are to the Tax Court Rules of                  
          Practice and Procedure.                                                     
                                     Background                                       
               Petitioners are married and lived in Fresno, California,               
          when they filed their petition.  Michael A. Milnes (petitioner)             
          is an attorney.                                                             
          A.   The Notices of Federal Tax Lien                                        
               On August 27, 1992, respondent filed with the Fresno County            
          Recorder’s Office a notice of Federal tax lien relating to                  
          petitioners’ income tax liability for tax year 1991.  On March              
          10, 1997, respondent filed with the Fresno County Recorder’s                
          Office a notice of Federal tax lien relating to petitioners’                
          income tax liabilities for tax years 1993 and 1995.                         
          B.   The Notice of Intent To Levy                                           
               On March 26, 2001, respondent issued to petitioners a Final            
          Notice of Intent to Levy and Notice of Your Right to a Hearing              
          relating to petitioners’ income tax liabilities for 1991, 1993,             
          and 1995.  On April 25, 2001, petitioners filed a Request for a             
          Collection Due Process Hearing, Form 12153, for tax years 1987-             
          951 in which they contended that:  (1) Respondent should abate              
          penalties relating to tax years 1988 and 1989; (2) respondent               


               1  Petitioners’ tax years 1987-90, 1992, and 1994 are not in           
          issue here because respondent’s notice of intent to levy did not            
          include those years; only 1991, 1993, and 1995 are at issue here.           




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