- 2 - MEMORANDUM OPINION NIMS, Judge: Petitioner petitioned the Court under section 6330(d)1 to review the determination of the Internal Revenue Service’s Office of Appeals sustaining a proposed levy on petitioner’s property related to petitioner’s year 2000 Federal income tax liability. Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect at relevant times. Petitioner resided in Virginia at the time she filed her petition. Background This case was submitted fully stipulated. The facts as stipulated are so found. Petitioner filed her Federal income tax return for 2000 on the basis of married filing separate. Petitioner’s reported tax liability included an alternative minimum tax liability (AMT) of $776,447, and “regular” tax in the amount of $10,100, bringing her total tax liability to $786,547. Her return reported Federal income tax withheld of $11,080, and estimated tax payments of $450,000, leaving a balance of tax due in the amount of $325,467. 1The petition refers initially to sec. 6330(c); however, this appears to be an inadvertence, since sec. 6330(d) is the statutory provision that provides for judicial review of a determination by the Internal Revenue Service Office of Appeals.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011