- 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