- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011