Sedrick Celestin - Page 3

                                        - 2 -                                         
               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           






Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011