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reference. At the time the petition was filed, petitioner was a
legal resident of Leesburg, Florida.
Petitioner seeks a review under section 6320(b) of the
filing of a notice of lien under section 6323 with respect to his
Federal income taxes for the years 1997, 2000, and 2001. As of
June 15, 2004, petitioner’s unpaid tax liabilities were $48,122,
$3,227.99, and $36,897.19, respectively, for 1997, 2000, and
2001. Prior to respondent’s issuance of the tax lien notice,
petitioner had made an offer in compromise for settlement of
these liabilities; however, that offer was not considered because
petitioner was not “compliant” in the filing of his 2002 Federal
income tax return and, additionally, had not made estimated tax
payments for the year 2003.
Petitioner filed Federal income tax returns for the 3 years
at issue. For the year 1997, petitioner filed as a single
person. Petitioner married Carolyn Bair during 1998, and they
filed joint Federal income tax returns for the 2 other years at
issue, 2000 and 2001. Petitioner’s spouse is not a party in this
proceeding.
Petitioner is an attorney and is engaged in the practice of
law. No notices of deficiency were issued with respect to the 3
years at issue. The unpaid taxes arise from underpayments by
petitioner of the taxes shown on his income tax returns.
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