James Weldon Aaron - Page 3

                                        - 2 -                                         
               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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