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The petition in this case was filed in response to a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330. Pursuant to sections 6320(c) and 6330(d),
petitioner seeks review of respondent’s filing of a notice of
Federal tax lien for his tax liabilities for 1997 and 1998. The
issue for decision is whether respondent’s collection action was
an abuse of his discretion.
Background
The stipulated exhibits and the exhibits received into
evidence are incorporated herein by reference. At the time the
petition in this case was filed, petitioner resided in Corona,
California.
Petitioner signed a stipulated decision in Sedrick Celestin
and Marie M. Paul, docket No. 8355-00, entered by this Court on
October 23, 2001. On February 4, 2002, respondent assessed the
deficiency of $44,545 and an accuracy-related penalty of $3,847
for 1997, as agreed in the stipulated decision. Petitioner filed
for bankruptcy in April of 2002.
Discussion
Section 6320 entitles a taxpayer to notice of his right to
request a hearing with the Internal Revenue Service (IRS) Office
of Appeals after a notice of lien is filed by the Commissioner in
furtherance of the collection of unpaid Federal taxes. The
taxpayer requesting the hearing may raise any relevant issue with
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