Kenneth A. Schrems - Page 2




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          July 31, 2001, petitioner’s unpaid income tax liabilities were as           
          follows:                                                                    
                           Year              Unpaid Liability                         
                           1994                   $13,776                             
                           1995                   15,526                              
                           1996                   12,897                              
               Respondent also assessed a $564 penalty pursuant to section            
          66821 relating to petitioner’s filing of a false Form W-4,                  
          Employee’s Withholding Allowance Certificate, relating to 1997.             
          On October 28, 2002, the Court granted respondent’s motion to               
          dismiss for lack of jurisdiction and to strike as to the taxable            
          year 1997.                                                                  
               On April 11, 2001, respondent filed a lien for income taxes,           
          interest, and penalties owed by petitioner relating to the years            
          in issue.  That same day, respondent issued petitioner Form 3172,           
          a Notice of Federal Tax Lien Filing and Your Right to a Hearing             
          Under IRC 6320 (Notice of Federal Tax Lien).                                
               On May 7, 2001, respondent received petitioner’s Form 12153,           
          Request for a Collection Due Process Hearing (Request).  In                 
          conjunction with his Request, petitioner sought discovery with              
          respect to 51 categories of documents including:  (1)                       
          “Documentary evidence of the internal revenue district, * * * in            
          which [petitioner] * * * [is] liable for federal tax”; (2) the              


               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code in effect for the years in issue.                 





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