- 5 - At the Court hearing on November 17, 2003, Fran argued with much vigor that, under her reading and close study of the Internal Revenue Code and regulations, she and her husband are not taxable on their wages and income. Fran pleads with the Court to provide her with a persuasive written explanation, if any exists, as to how she and her husband are liable for Federal income taxes on her husband’s wages, on her fee income, on the early retirement account distributions and on the interest income. Discussion We note initially that because petitioners received a notice of deficiency relating thereto petitioners’ Federal income tax liability for 1997 is not before us in this action. Goza v. Commissioner, 114 T.C. 176, 180-181 (2000). Our jurisdiction herein is limited to a review of respondent’s discretion in filing a notice of Federal tax lien to upgrade respondent’s creditor status vis-a-vis petitioners’ other creditors. Sec. 6323; Sego v. Commissioner, 114 T.C. 604, 610 (2000). On that narrow question as to respondent’s discretion we hold for respondent. Petitioners have offered no basis on which we could find any error in respondent’s discretionary determination to proceed with the filing of a notice of Federal tax lien relating to the 1997 Federal income tax deficiency,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011