Richard Mark Hansen - 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 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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