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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.
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Last modified: May 25, 2011