- 2 -
The petition in this case was filed in response to a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330 (notice of determination). Pursuant to sections
6320(c) and 6330(d), petitioner seeks review of respondent’s
determination to proceed with collection of his tax liability for
1999. The issue for decision is whether the Appeals officer
abused his discretion in sustaining a proposed levy to collect
petitioner’s unpaid 1999 tax liability.
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. At the time the
petition in this case was filed, petitioner resided in Buena
Park, California.
Petitioner, a former software system engineer, is a teacher
of mathematics and computer technology in the Los Angeles public
school system. In April of 2002 he married his second wife.
Petitioner did not pay Federal withholding taxes on his income
for 1999. He did not file his Federal income tax return for 1999
until February 23, 2004.
On May 22, 2004, respondent issued to petitioner a notice of
intent to levy regarding his unpaid tax liability for 1999.
Petitioner filed a Form 12153, Request for a Collection Due
Process Hearing, dated June 12, 2004, as to 1999, 2000, and 2001.
Respondent had sent to petitioner a notice of Federal tax lien
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011