- 4 - request. Petitioner did not respond. Ms. Melick sent a second letter on October 8, 2003, requesting that petitioner respond within 15 days. Petitioner did not respond. Respondent conducted an administrative review of petitioner’s file. On November 25, 2003, respondent sent petitioner notice of determination sustaining the filing of the Federal tax lien for 1998. On December 23, 2003, petitioner timely filed a petition with the Court. Upon order of the Court, petitioner filed an amended petition on February 24, 2004, seeking review of the underlying tax liability and relief from the lien collection action under section 6320. The parties have stipulated that, subsequent to petitioner’s filing with this Court, an installment agreement has been entered into for petitioner’s outstanding tax liability, and that any overpayments resulting from the allowance of petitioner’s schedule A expense deduction for 1996 will be applied to the outstanding tax liability for 1998. At trial, petitioner raised a reasonable cause defense to the section 6651 additions to tax, citing his 1996 surgery. OPINION Pursuant to section 6330(d)(1), within 30 days of the issuance of the notice of determination, the taxpayer may appeal the determination to this Court if we have jurisdiction over thePage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011