William Reese - Page 2

                                         -2-                                          
          collection by levy of petitioner’s Federal income tax liability             
          for 1988 to 1992, inclusive, plus accrued interest and failure to           
          pay penalty under section 6651(a)(3).  Unless otherwise                     
          indicated, all section references are to sections of the Internal           
          Revenue Code in effect for the years in issue, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            
          Petitioner resided in Reston, Virginia, at the time the petition            
          was filed.                                                                  
                                     Background                                       
               Under “Brief Background,” the notice of determination                  
          states, among other things, that                                            
               The outstanding tax liabilities are the result of TC                   
               300 additional tax assessments because Mr. Reese was a                 
               non-filer.[1]  When the required Notices of Deficiencies               
               [for 1988 to 1992, inclusive,] were issued, * * * [Mr.                 
               Reese] petitioned Tax Court.  The TC 300 assessments                   
               and all applicable penalties and interest are in                       
               accordance with the Tax Court Decision documents for                   
               each year.                                                             
              Under Relevant Issues Presented by the Taxpayer, the Notice            
          states that                                                                 
               IRC 6330(c) allows the taxpayer to raise any relevant                  
               issue relating to the unpaid tax.  Form 12153 as                       
               prepared by Mr. Reese claims that the amounts                          
               outstanding are in error:  that the Philadelphia                       
               Service Center transposed numbers from the Tax Court                   
               Decision Documents, and have [sic] refused to abate the                
               incorrect amounts.                                                     


               1TC 300, 1 Audit, Internal Revenue Manual (CCH), exhibit               
          4.4.1-1, at 7425, is a so-called transaction code number used               
          internally by the Internal Revenue Service.  It has no                      
          significance for purposes of this case.                                     




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011