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of filing a notice of Federal tax lien; and (2) whether
respondent’s Appeals officer abused his discretion in sustaining
the collection action of issuance of a notice of jeopardy levy.4
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the first, second, third, and fourth
supplemental stipulations of facts, and the attached exhibits are
incorporated herein by this reference. The stipulations of facts
include transcripts and exhibits from petitioner’s criminal
prosecution, which commenced on March 16, 1998. The stipulations
incorporate the trial testimony of the witnesses from the
criminal prosecution as though it were given during the course of
the trial in this Court.
The petition in docket No. 15557-99 was filed on September
28, 1999. The petition in docket No. 4590-00L was filed on April
25, 2000. When he filed the petitions in these cases, petitioner
was incarcerated in a Federal penitentiary in Elkton, Ohio. Upon
release from prison in 2002, petitioner resided in Wabash,
Indiana.
Petitioner married Judith Ann Mosier on or about June 28,
1959. Michael Hoover and Tadd Hoover are two of the couple’s
children. Petitioner and Ms. Mosier divorced on July 25, 1990.
4 The taxes involved in the collection action are the income
tax liabilities for 1989, 1990, 1991, and 1992 that are in issue
in docket No. 15557-99.
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