- 3 - 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’sPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011