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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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Last modified: May 25, 2011