Leonard Parker - Page 2

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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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