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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 on July 12, 2004. The issue
for decision is whether respondent abused his discretion in
sustaining a notice of Federal tax lien filed against petitioner.
Background
Some of the facts have been stipulated, and they are so
found. The record consists of the stipulation of facts with
attached exhibits, an additional exhibit introduced at trial, and
the testimony of petitioner. At the time of filing the petition,
petitioner resided in Sebring, Florida.
Respondent made assessments against petitioner for income
taxes, related penalties, and interest for the taxable years
1994, 1995, 1996, and 2002. Respondent sent a notice and demand
for payment for each of the years at issue, but petitioner failed
to remit payment.
In February 2003, petitioner submitted an offer-in-
compromise (OIC), in which he offered to pay $3,000 to compromise
his tax liabilities for the taxable years 1994, 1995, and 1996.1
The OIC was based on doubt as to collectibility and promotion of
effective tax administration. In a written statement attached to
1 The OIC also included the taxable years 1992 and 1993 but
did not include the taxable year 2002. The taxable years 1992
and 1993 are not before the Court.
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