Chi Wai - Page 2

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                                 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.            




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