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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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