- 2 -
respect to petitioner’s unpaid income taxes, penalties, and
interest for 1997-2002.
The issues for decision are:
1. Whether we have jurisdiction to review respondent’s
determination to proceed with collection of penalties under
section 6682 for 2002 and under section 6702 for 1997-2001. We
hold that we do not.
2. Whether petitioner may dispute his income tax liability
for 1998 in this proceeding. We hold that he may not.
3. Whether petitioner is liable for tax in the amount
respondent contends for 2001 and 2002. We hold that he is.
4. Whether respondent’s determination that it was
appropriate to file a notice of lien with respect to petitioner’s
income taxes, additions to tax, and penalties (other than those
under sections 6682 and 6702) for 1998, 2001, and 2002 was an
abuse of discretion. We hold that it was not.
FINDINGS OF FACT
A. Petitioner
Petitioner resided in Salt Lake City, Utah, when the
petition was filed. He was a driver for Viking Freight, Inc.
(Viking) in 1998, for which he received wages of $50,361.82 in
that year.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011