- 2 - and 1994 Federal income tax liabilities. The issue for our consideration is whether respondent abused his discretion by determining to proceed with the proposed levy. FINDINGS OF FACT2 At the time of the filing of the petition in this case, petitioner resided in Rockville, Maryland. On April 11, 2001, petitioner was provided with the opportunity to contest his 1992, 1993, and 1994 income tax deficiencies in a trial before this Court. On December 12, 2001, the Court held in a Summary Opinion, inter alia, that petitioner was engaged in a money- lending business for the years 1992 to 1994 and was allowed to deduct certain expenses associated with that business. See Hajiyani v. Commissioner, T.C. Summary Opinion 2001-183. In the above-referenced deficiency proceeding, the parties were required to provide the Court with computations reflecting the holdings in T.C. Summary Opinion 2001-183 for purposes of entry of decision. See Rule 155. Respondent submitted a computation, but petitioner did not. After a time, respondent moved for an entry of decision in accord with his proposed computation, which was based on the Court’s Summary Opinion. On February 22, 2002, petitioner, through his attorney, Kenneth Wall, filed an objection to the entry of decision, 2The parties’ stipulation of facts is incorporated by this reference.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011