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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 April 8, 2004. Pursuant to
sections 6320(c) and 6330(d), petitioner seeks review of
respondent’s determination sustaining the filing of a notice of
Federal tax lien against petitioner. The issue for decision is
whether petitioner may dispute the underlying tax liability for
any of the years in issue and, if so, whether any adjustment is
appropriate.
Background
Some of the facts have been stipulated, and they are so
found, except as described below. The record consists of the
stipulation of facts with attached exhibits, additional exhibits
admitted during trial, and the testimony of petitioner and Alyce
Wong, who is benefits supervisor for the San Francisco City and
County Employees Retirement System. At the time of filing the
petition, petitioner resided in San Francisco, California.
Respondent made assessments against petitioner for income
taxes and related penalties and interest for the taxable years
1994, 1995, 1996, 1997, and 1998. Respondent also assessed for
collection costs for the taxable year 1994.
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