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This proceeding arises from a petition for judicial review
filed in response to a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 (notice of
determination) sent to petitioner. Pursuant to sections 6320(c)
and 6330(d), petitioner seeks review of respondent's
determination to proceed with collection of his income tax
liabilities of $7,154.21 for 1992, $439.61 for 1998, and $135.51
for 2000. The issue for decision is whether the settlement
officer abused her discretion in sustaining, as an appropriate
collection measure, the filing of a Notice of Federal Tax Lien on
petitioner's property and rights to property.
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. Petitioner
resided in Southwest Harbour, Maine, at the time the petition was
filed.
Background
Petitioner filed a Form 1040, U.S. Individual Income Tax
Return, dated April 19, 1997, for 1992 reflecting a tax liability
of $3,608. In June 1997, respondent assessed additions to tax
for late filing and failure to pay tax of $811.80 and $902,
respectively. Including interest, petitioner's outstanding tax
liability for 1992 is $7,154.21 as of the date of the filing of
the Notice of Federal Tax Lien. As interest is still accruing,
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