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Collection Action(s) Under Section 6320 (Lien) of the Internal
Revenue Code.1 The issue for decision is whether respondent may
proceed with collection, in the form of a filed tax lien, of
petitioner’s Federal income tax liabilities for the 1990, 1993,
1994, 2000, and 2001 taxable years.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At the time this petition
was filed, petitioner resided in Altamonte Springs, Florida.
Petitioner failed to file a Federal income tax return for
1990. Petitioner filed untimely for the 1993, 1994, 1996, and
1997 taxable years and did not remit payment of the balances due.
Petitioner filed timely for 1999, 2000, and 2001, but again did
not remit sufficient payment.
The vast majority of petitioner’s tax liabilities arose in
1993 and 1994 when petitioner was president of Public Telephone
Corporation and earned over $100,000 in salary each year. In
1995, Public Telephone Corporation was seized by the Federal
Trade Commission and put into receivership. Thereafter,
petitioner held a series of seasonal and odd jobs and relied on
friends and family for housing, food, and other bare necessities.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) of 1986, as amended.
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