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review of respondent’s determination sustaining a Federal tax
lien. After concessions,2 the issues for decision are: (1)
Whether petitioner is liable for additions to tax under section
6651(a)(1) and (a)(2) for 1998; and (2) whether respondent abused
his discretion in sustaining the Federal tax lien.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in San Bruno, California.
Petitioner is a practicing attorney.
Petitioner had his gall bladder removed in 1996 and was off
work for 4 months. After his recovery, petitioner was able to
continue his legal practice, pay business expenses, manage two
rental properties, and take care of two minor children.
On April 8, 2001, petitioner filed a Form 1040, U.S.
Individual Income Tax Return, for 1998, showing a tax due of
$8,122. Petitioner made no payments at the time of filing.
1(...continued)
Internal Revenue Code in effect for the years in issue.
2 The parties disagreed over petitioner’s Schedule A,
Itemized Deductions, for 1996, but respondent now concedes that
petitioner is entitled to the deduction. The parties have also
stipulated that, subsequent to his filing with this Court,
petitioner fully paid his 1996 and 1997 tax liabilities,
including additions to tax pertaining to those years. Upon
payment, the Federal tax liens for 1996 and 1997 were released.
Only 1998 remains at issue.
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