- 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. Background 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 Procedure.Page: Previous 1 2 3 4 5 6 NextLast modified: November 10, 2007