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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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