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Respondent issued to petitioner a Notice of Determination
Concerning Collection Action(s) Under Sections 6320 And/Or 6330
(notice of determination). This Court must decide whether
respondent abused his discretion in determining that the filing
of the Notice of Federal Tax Lien was appropriate.
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Atlanta, Georgia, at the time he
filed his petition.
Petitioner did not timely file his Form 1040, U.S.
Individual Income Tax Return, for 1991. In addition, petitioner
did not timely file Federal income tax returns for 1992 through
2001.
On December 6, 1993, respondent prepared a Substitute For
Return for taxable year 1991.
On February 8, 1997, respondent issued to petitioner’s
employer, PWJ Incorporated (PWJ), a Form 668-W(c), Notice of Levy
on Wages, Salary, and Other Income (wage levy), in the amount of
$12,461.15.
On April 8, 2002, respondent sent to petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 (notice of lien).
On May 10, 2002, respondent received petitioner’s Request
for a Collection Due Process Hearing (Appeals Office hearing) in
response to the notice of lien. In his request for an Appeals
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