- 2 - filing of a tax lien relating to petitioner’s 1998 tax liability was appropriate.1 The sole issue for decision is whether respondent’s determination that the filing of a tax lien relating to petitioner’s 1998 tax liability was appropriate was an abuse of discretion. We hold that it was not. FINDINGS OF FACT A. Petitioner and His 1998 Income Tax Return Petitioner resided in Houston, Texas, when he filed the petition in this case. Petitioner reported on his 1998 income tax return that he had no wages, other income, or tax liability, and that he had taxes withheld of $2,935.30. He claimed a refund of $2,935.30. Petitioner attached a letter to his 1998 return in which he contended that: Wages are not income; petitioner is not required by law to file a return or pay income tax; and respondent failed to provide petitioner with a copy of the law requiring him to pay income tax. B. Notice of Deficiency and Bankruptcy On September 8, 1999, respondent sent a notice of deficiency for 1998 to petitioner at the address shown on petitioner’s 1998 return. In it, respondent determined a deficiency in 1 Unless otherwise indicated, section references are to the Internal Revenue Code as amended.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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