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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 November 4, 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 and
supplemental stipulation of facts with attached exhibits,
additional exhibits introduced at trial, and the testimony of
petitioner. At the time of filing the petition, petitioner
resided in Emeryville, California.
Petitioner filed Federal income tax returns for the taxable
years 2000 and 2001 but did not pay the taxes reported thereon.
Respondent assessed the taxes shown on the returns, as well as
related penalties and interest, and filed a notice of Federal tax
lien against petitioner on May 29, 2003, in the total amount of
$13,220.86. Respondent sent petitioner a Notice of Federal Tax
Lien Filing and Your Right to a Hearing Under IRC 6320 on June 3,
2003.
Petitioner timely submitted a Form 12153, Request for a
Collection Due Process Hearing. Petitioner also submitted an
offer-in-compromise (OIC), in which he offered to pay $3,800 to
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