Orlando Bujosa - Page 3




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          otherwise indicated, all subsequent section references are to the           
          Internal Revenue Code as amended, and all Rule references are to            
          the Tax Court Rules of Practice and Procedure.                              
               This case arises from a petition for judicial review filed             
          in response to a Notice of Determination Concerning Collection              
          Action(s) Under Section 6320 and/or 6330 (notice of                         
          determination).  The issues for decision are: (1) Whether                   
          petitioner may challenge his underlying tax liabilities; (2) if             
          he may, whether remand to Appeals is necessary; and (3) if remand           
          is not necessary, whether respondent’s rejection of petitioner’s            
          offer-in-compromise constitutes an abuse of discretion.                     
                                     Background                                       
               This case was submitted fully stipulated pursuant to Rule              
          122, and the facts as stipulated are so found.  The stipulations            
          of the parties, with accompanying exhibits, are incorporated                
          herein by this reference.  At the time he filed the petition,               
          petitioner resided in Linden, New Jersey.                                   
               Petitioner earned nonemployee compensation from L&P Trucking           
          in the amounts of $22,815 for 1987 and $20,830 for 1988, which              
          amounts were reported on Forms 1099-MISC, Miscellaneous Income.             
          In 1988 petitioner also received $2,341 in wages reported on Form           
          W-2, Wage and Tax Statement (Form W-2), from The Newark Group and           
          wages reported on Form W-2 in the amount of $45 from Beacon Hill            
          Club.  However, petitioner failed to file income tax returns for            







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