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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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Last modified: May 25, 2011