- 2 - The petition in this case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. Pursuant to sections 6320(c) and 6330(d), petitioner seeks review of respondent's filing of a Notice of Federal Tax Lien for his 1991, 1992, 1993, and 1994 tax liabilities. The issue for decision is whether respondent abused his discretion by filing the notice of Federal tax lien as a method of collecting petitioner’s tax liabilities. Background The stipulated facts and exhibits received into evidence are incorporated herein by reference. At the time the petition in this case was filed, petitioner resided in Colorado. Petitioner failed to file tax returns for any of the years 1991 through 1994. Petitioner’s Federal income tax returns were examined by respondent beginning in February of 1995. As part of the audit, petitioner appeared at the office of the Internal Revenue Service (IRS). Respondent proposed a determination that petitioner, despite earning substantial income, failed to file Federal income tax returns for all the years under examination. When asked, petitioner admitted to not filing tax returns but objected to the proposed deficiency, asserting that respondent’s proposed action was unconstitutional.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011