- 2 -
This collection review case is before the Court on
respondent’s motion for summary judgment. Respondent issued
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 (notice of
determination) for unpaid Federal income taxes and related
liabilities for 1992, 1994, 1996, and 2000. The notice of
determination relates to a notice of Federal tax lien filed on
April 10, 2003, for the above years in the approximate amount of
$9,027.
The issue for decision is whether, in the context of
respondent’s motion for summary judgment, respondent’s
determination to proceed with the filing of a Federal tax lien
was an abuse of discretion.
Background
Petitioners resided in Tucson, Arizona, at the time the
petition was filed.
Petitioners filed 1992, 1994, 1996, and 2000 Federal income
tax returns. The respective amounts of payments and credits
relating to the returns in issue were less than the tax
liabilities reported. Accordingly, there is a balance due and
owing with respect to each of the years in issue. Petitioner,
Michael Brewer (hereinafter petitioner) is a U.S. Marine Corps
veteran. He suffers from post traumatic stress disorder from his
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011