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section 6330(d), petitioner seeks review of respondent’s
determination. The issues for decision are whether respondent
abused his discretion in sustaining the filing of a Federal tax
lien and whether the Court should impose a penalty under section
6673(a).
FINDINGS OF FACT
At the time the petition was filed, petitioner resided in
Methuen, Massachusetts.
On April 25, 2000, respondent received petitioner’s 1999
Federal income tax return. Petitioner reported tax withheld of
$2,235, claimed a refund of $2,235, and entered zeros on all
other lines. Petitioner attached to the return a two-page letter
disputing the constitutionality of the Federal income tax laws
and claiming that no law made him liable to pay tax. Respondent
informed petitioner that his 1999 return could not be filed.
On June 29, 2001, respondent received petitioner’s 2000
Federal income tax return. Petitioner reported tax withheld of
$895, claimed a refund of $895, and entered zeros on all other
lines. Petitioner attached to the return a two-page letter
identical to the letter attached to his 1999 return.
1(...continued)
the Internal Revenue Code, as amended. All amounts are rounded
to the nearest dollar.
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