- 2 - William J. McCorkle, pro se. Pamela L. Mable, for respondent. OPINION HALPERN, Judge: This case is before the Court to review a determination made by respondent’s Appeals Office (Appeals) that respondent was warranted in filing a notice of Federal tax lien (the notice of Federal tax lien or NFTL) against petitioner with respect to his Federal income tax liability for 1996 (1996 tax liability). We review that determination pursuant to sections 6320(c) and 6330(d)(1).1 Petitioner assigns error to Appeals’ determination on the grounds that Appeals erred in determining that a $2 million remittance made by petitioner to the Internal Revenue Service (IRS) on or about May 16, 1997 (the $2 million remittance), did not satisfy the 1996 tax liability. Appeals determined that the $2 million remittance did not satisfy the 1996 tax liability because that amount had been refunded to the U.S. Marshals Service (Marshals Service) pursuant to an order of the court in a non-tax criminal case involving petitioner. The order specified that the $2 million was subject to criminal forfeiture pursuant to 18 U.S.C. sec. 982 (2000). There being little dispute as to the underlying facts, the parties have each 1 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011