- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011