- 2 - determination relates to petitioners’ Federal income tax liabilities for 1992, 1993, 1994, 1995, 1996, and 1997. Petitioners’ liability for the underlying taxes, interest, and penalties is not disputed. The issue for decision is whether respondent’s rejection of petitioners’ three proposed alternatives to collection constitutes an abuse of discretion. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time of filing the petition, petitioners resided in Lebanon, Tennessee. Petitioner Donald G. Willis2 operates a locksmith business as a sole proprietorship. Petitioner subcontracts much of the locksmith work. In addition, petitioner derives income from a part-time ministry. Petitioner Claudia A. Willis is not employed outside the home. On January 30, 2001, respondent sent to petitioners a final notice of intent to levy with respect to petitioners’ outstanding Federal income taxes, interest, and penalties for 1992 through 1997 (cumulative liability). On March 1, 2001, respondent received petitioners’ timely request for a collection due process hearing. After submitting to respondent for consideration certain personal financial information relating to petitioners, on May 9, 2 Hereinafter, unless otherwise indicated, references to petitioner in the singular are to petitioner Donald G. Willis.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011