Leonard O. Parker, Jr. - Page 3

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               Petitioner resided in Torrance, California, when he filed              
          the petition.                                                               
          A. Petitioner’s 1992-94 Tax Returns                                         
               Petitioner filed tax returns for 1992-94 in which he                   
          reported income of $37,353 for 1992, $12,265 for 1993, and $8,123           
          for 1994.  Petitioner paid no tax for those years except for $156           
          that he paid with his 1994 return.  Respondent assessed the tax             
          reported on petitioner’s returns for those years.                           
          B.   Filing of the Notice of Federal Tax Lien and the Hold Placed           
               on Collection Actions by the Taxpayer Advocate                         
               In 1999, petitioner filed a Form 656, Offer in Compromise,             
          for 1992-94 and a request to abate interest and penalties with              
          respect to 1992-94 with respondent’s New Orleans, Louisiana,                
          Taxpayer Advocate’s Office.  Petitioner submitted another offer             
          in compromise and request to abate interest and penalties after             
          respondent lost his first one.                                              
               On March 21, 2001, respondent’s Automated Collection Service           
          (ACS) requested that a notice of Federal tax lien be filed                  
          relating to petitioner’s 1992-94 tax years.  On March 29, 2001,             
          an employee in respondent’s office in New Orleans prepared and              
          signed a notice of Federal tax lien for petitioner’s 1992-94 tax            
          years.  On April 5, 2001, respondent filed with the Orleans                 
          Parish Recorder’s Office a notice of Federal tax lien relating to           
          petitioner’s tax liabilities for tax years 1992-94.  Also on that           
          day, Ms. Claudis M. Holmes (Holmes), an employee of respondent’s            





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