William J. McCorkle - Page 2

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               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.            




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