- 2 - 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.Page: Previous 1 2 3 4 5 6 Next
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