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and additions to tax under section 6651(a)(1) for petitioner’s
1999, 2000, 2001, 2002, and 2003 tax years. The tax liabilities
arise from the underpayment of taxes shown on income tax returns
for the 5 years. No notices of deficiency have been issued for
the 5 years, and petitioner does not question the underlying
liabilities.
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and made part hereof.
Petitioner’s legal residence at the time the petition was filed
was Orlando, Florida.
This case arises over the issuance by respondent of a notice
of determination concerning collection actions under section 6320
and/or 6330 with respect to petitioner’s 1999, 2000, 2001, 2002,
and 2003 tax years. The income tax returns for these years were
not filed timely, and petitioner failed to pay all or some of the
tax shown as due and owing on each of the returns.2 The dispute
in this case arises over respondent’s issuance of a notice of
Federal tax lien. Petitioner seeks to have that tax lien
withdrawn. Prior to issuance of the tax lien, respondent had
2At the time the notice of determination was issued,
petitioner’s unpaid taxes were as follows:
1999 $15,849.29
2000 1,206.91
2001 6,118.08
2002 4,460.10
2003 7,572.86
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Last modified: May 25, 2011