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petitioner’s unpaid income tax liabilities for 1986 through 1996
should proceed.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner is a member of a federally recognized Indian tribe
known as the Coeur d’Alene Indian Tribe. He resided in Idaho at
the time that he filed his petition. Petitioner operates a
business on property that is held in trust by the United States
for the benefit of petitioner.
Petitioner did not file a Form 1040, U.S. Individual Income
Tax Return, for any year from 1986 through 1992. Petitioner
filed untimely returns for 1993 through 1996; however, the tax
due was not paid at the time of the filing of any of these
returns.
Petitioner’s unpaid taxes, penalties, and interest were duly
assessed. Based on the unpaid balances of the assessed tax
liabilities, penalties, and interest, the IRS filed Forms 668,
Notice of Federal Tax Lien, with respect to 1986 through 1996.
The liens for the 1986 through 1991 taxes were filed in Kootenai
and Benewah Counties, Idaho, on February 20, 1997. The liens for
the 1992 through 1995 taxes were filed in Kootenai County on
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