Wesley Sherwood - Page 2

                                        - 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