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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 sections 6320(c)
and 6330(d), petitioner seeks review of respondent’s
determination to proceed with collection of his income tax
liabilities, which were $54,282.80 for 1997, $4,011.31 for 1998,
and $12,744.35 for 2000 at the time of the notice of
determination. The issue for decision is whether the settlement
officer abused his discretion in sustaining, as an appropriate
collection measure, the filing of a Notice of Federal Tax Lien
(NFTL) on petitioner’s property and rights to property.
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. Petitioner
resided in Los Angeles, California, at the time the petition was
filed.
Background
A. Petitioner’s Tax Returns
1. Petitioner’s 1997 Tax Return
Petitioner, a self-employed real estate broker, timely filed
Form 4868, Application for Automatic Extension of Time to File
U.S. Individual Income Tax Return, for 1997. Petitioner then
timely filed without remittance a Form 1040, U.S. Individual
Income Tax Return, for 1997. Attached to petitioner’s 1997
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Last modified: May 25, 2011