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determination), in which respondent sustained the filing of a
Federal tax lien for petitioner’s 1993, 1995, and 1996 tax
liabilities. Petitioner had previously made two offers-in-
compromise regarding these tax liabilities. Respondent rejected
the first offer and returned the second.
The issue for consideration is whether respondent abused his
discretion by sustaining the filing of the Federal tax lien.
FINDINGS OF FACT2
Petitioner resided in Pompano Beach, Florida, when the
petition in this case was filed. He was self-employed for
taxable years 1993, 1995, and 1996 (collectively, the subject
years), operating a business known as “Professional
Investigations and Consulting Inc.”. Petitioner filed untimely
tax returns for all subject years, with unpaid tax liabilities
for 1995 and 1996 and a small refund for 1993. At all relevant
times, petitioner had an unpaid Federal income tax liability
outstanding for each of the subject years, much of which arose
out of self-assessment.3 Petitioner was not married and did not
file joint returns for the taxable years under consideration.
2 The parties’ stipulation of facts is incorporated by this
reference.
3 All of the 1995 and 1996 liabilities arose from unpaid tax
shown on petitioner’s self-assessed tax returns, while an audit
for the 1993 taxable year resulted in a deficiency determination
for that taxable year.
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