Larry Bruce - Page 3




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               Petitioner is a long-haul trucker who spends a great deal of           
          time on the road.  In 2003, he won more than $1 million dollars             
          from a slot machine in New Jersey.  Petitioner timely filed an              
          income tax return and reported the winnings, calculating income             
          tax due of $326,772 offset by withholding of $2,188, but paid               
          nothing beyond the withheld amount.  Respondent assessed the                
          reported tax plus additions to tax and interest on May 31, 2004.            
               Respondent’s revenue officer attempted negotiations to                 
          secure payment of the assessed balance to no avail.  During a               
          meeting with the revenue officer on May 10, 2005, petitioner                
          filled out a Form 433-A, Collection Information Statement for               
          Wage Earners and Self-Employed Individuals, but did not provide             
          any supporting documentation.  Ignoring requests and suggestions            
          by respondent’s revenue officer, petitioner took no steps toward            
          payment of his tax obligation.                                              
               Respondent sent to petitioner a Final Notice - Notice of               
          Intent to Levy and Notice of Your Right to a Hearing on May 10,             
          2005.  Respondent filed a Notice of Federal Tax Lien on, or                 
          around, May 12, 2005, and sent petitioner a Notice of Federal Tax           
          Lien Filing and Your Right to a Hearing Under IRC 6320 on May 19,           
          2005.  Petitioner mailed requests for Appeals hearings on June              
          10, 2005.  The mailing was timely with respect to the lien                  
          notice, but not with respect to the levy notice.  Attachments to            








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