Lionel Brown - Page 3

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               This proceeding arises from a petition for judicial review             
          filed in response to a Notice of Determination Concerning                   
          Collection Action(s) Under Section 6320 and/or 6330 (notice of              
          determination) sent to petitioner.  Pursuant to section 6330(d),            
          petitioner seeks review of respondent’s determination to proceed            
          with collection of his income tax liabilities for 1997 and 2000.            
          The issue for decision is whether respondent’s Appeals officer              
          abused her discretion in sustaining a proposed levy to collect              
          petitioner’s unpaid income tax liabilities for 1997 and 2000.               
               The stipulation of facts and the exhibits received into                
          evidence are incorporated herein by reference.  Petitioner                  
          resided in Glendora, California, at the time the petition was               
          filed.                                                                      
                                     Background                                       
               Petitioner timely filed a Form 1040, U.S. Individual Income            
          Tax Return, for 1997 reflecting a tax liability of $7,135, but              
          failed to pay the liability in full.  Respondent assessed the tax           
          as well as an addition to tax for failure to pay tax of $7.32               
          and credited petitioner’s account for Federal withholding taxes             
          of $4,449.  Including interest, petitioner’s outstanding tax                
          liability for 1997 was $2,532.61 as of the date of the Notice of            
          Intent to Levy.  Petitioner has not made any other payments                 
          toward his liability for 1997.                                              







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