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action(s) under section 6320 and/or 6330,2 which upheld
respondent’s NFTL.3
The issues for decision presented by petitioner’s timely
filed petition with this Court are:
1. Whether petitioner is liable for the deficiencies
assessed by respondent. We hold petitioner is liable for the
deficiencies because petitioner has not satisfied the conditions
that would entitle him in this proceeding to contest respondent’s
deficiency determinations or assessments; and
2. whether respondent abused his discretion in sustaining
the filing of the Federal tax lien against petitioner’s property
to secure petitioner’s outstanding income tax liabilities for tax
years 1992 through 1994. We hold respondent did not abuse his
discretion in so doing.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
3On Mar. 8, 1999, respondent sent petitioner a final notice
of intent to levy and notice of the right to a hearing with
respect to his total unpaid tax liabilities; petitioner did not
file a timely request for a sec. 6330 hearing. After an
equivalent hearing, respondent upheld the proposed levy. We do
not have jurisdiction to consider the proposed levy. See infra
p. 16. However, because petitioner has conflated the lien and
levy issues and made some of the same arguments with respect to
both of them, we sometimes refer to the proposed levy in
considering petitioner’s arguments against the lien.
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