Kenneth Hawkins - Page 2

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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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