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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 December 30, 2003. Pursuant
to sections 6320(c) and 6330(d), petitioner seeks review of
respondent’s determination sustaining the filing of two notices
of Federal tax liens against petitioner.
The issues for decision are: (1) Whether petitioner’s case
regarding the filing of the notices of Federal tax liens is moot;
(2) whether petitioner may raise the underlying tax liability for
any of the years in issue, and if so, whether any adjustment is
appropriate; and (3) whether respondent abused his discretion in
failing to abate interest and additions to tax.
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Phoenix, Arizona, at the time the
petition was filed.
Background
Petitioner filed his 1995 Federal income tax return on June
12, 1996. Petitioner and his wife timely filed joint 1996, 1997,
and 1998 Federal income tax returns.1
1 Petitioner’s wife, Kristin K. Demos, is not a party to
these proceedings because she did not request a hearing and she
did not file a petition.
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Last modified: May 25, 2011