- 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
Last modified: May 25, 2011