Edward G. Castleman - Page 2

                                        - 2 -                                         
          June 2006.1  The issue for decision is whether respondent abused            
          his discretion in sustaining a notice of Federal tax lien filed             
          against petitioner.                                                         
               Some of the facts have been stipulated, and they are so                
          found.  The record consists of the stipulation of facts with                
          attached exhibits, additional exhibits introduced at trial, and             
          the testimony of petitioner.  At the time the petition was filed,           
          petitioner resided in Fort Myers, Florida.                                  
               Petitioner filed tax returns for 1996 and 1997 but did not             
          pay all the tax reported thereon.  Respondent issued petitioner a           
          notice of deficiency for the taxable year 1996.  Petitioner did             
          not file a petition for judicial review, and respondent assessed            
          the additional tax shown on the notice.  Respondent accepted                
          petitioner’s return for 1997 and therefore did not issue a notice           
          of deficiency for that year.                                                
               Respondent issued petitioner a Notice of Intent to Levy and            
          Notice of Your Right to a Hearing (notice of intent to levy) for            
          the taxable years 1996 and 1997 on February 23, 2004.  Petitioner           
          did not request an administrative hearing in response to the                
          notice of intent to levy.                                                   

               1  Section references are to the Internal Revenue Code and             
          Rule references are to the Tax Court Rules of Practice and                  

Page:  Previous  1  2  3  4  5  6  Next 

Last modified: November 10, 2007