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The issues for decision are: (1) Whether the Court lacks
jurisdiction under section 6330(d)(1)1 with regard to 1998; and
(2) whether there was an abuse of discretion in the determination
that the proposed collection action for 1999 should be sustained.
Background
Some of the facts have been stipulated. The stipulated
facts and the attached exhibits are incorporated herein by this
reference.
At the time of the filing of the petition, petitioners
resided in La Grange Park, Illinois. Mr. Orum has lived at the
same address his entire life. Mr. Orum is a patent attorney, and
Mrs. Orum is a zookeeper.
Petitioners filed joint Federal income tax returns for 1998
and 1999 on November 29, 1999, and November 20, 2000,
respectively, but did not make full payments of the tax
liabilities when the returns were filed.
On November 29, 1999, respondent assessed tax liabilities of
$63,683 plus additions to tax for 1998. Respondent issued
petitioners three notices of demand for payment of the 1998 tax
liabilities and additions to tax on November 29, 1999, January 3,
2000, and February 7, 2000.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended. Amounts are rounded to
the nearest dollar.
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