Marty J. Meehan - Page 2

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               THORNTON, Judge:  Pursuant to sections 6320(c) and 6330(d),            
          petitioner filed a petition for review of an Appeals Office                 
          determination sustaining a notice of Federal tax lien filing.1              
          The primary issue is whether petitioner is entitled to a section            
          6330 Appeals Office hearing with respect to his challenge of a              
          levy of his severance pay that occurred after the effective date            
          of section 6330 pursuant to a continuing wage levy that was                 
          served on petitioner’s employer before the effective date of                
          section 6330.                                                               
               The parties submitted this case fully stipulated pursuant to           
          Rule 122.  When petitioner filed his petition, he resided in                
          Oswego, New York.                                                           
          Petitioner’s 1988-94 Tax Liabilities                                        
               Petitioner failed to pay Federal income taxes that he owed             
          for taxable years 1988, 1989, 1990, 1991, 1992, 1993, and 1994.             
          Respondent filed various Notices of Federal Tax Lien with respect           
          to these unpaid taxes.2  On or about October 21, 1997, respondent           

               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code as amended, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           
               2 In 1991, respondent filed a Notice of Federal Tax Lien for           
          petitioner’s 1988 and 1989 income tax liabilities.  In 1994,                
          respondent filed a second Notice of Federal Tax Lien for                    
          petitioner’s 1990, 1991, 1992, and 1993 income tax liabilities.             

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