- 2 - 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 onPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011