- 2 -
respondent’s Appeals Office abused its discretion in determining
to proceed with collection of petitioner’s tax liabilities for
taxable years 1994 and 1995.
Background
None of the facts were stipulated. At the time of filing
the petition in the instant case, petitioner resided in Orlando,
Florida.
Petitioner failed to file timely income tax returns for
taxable years 1994 and 1995. On March 11, 2002, petitioner filed
late his income tax returns for the taxable years 1994 and 1995.
On February 25, 2000, respondent sent petitioner the Notices
of Deficiency for taxable years 1994 and 1995. On May 16, 2003,
respondent mailed to petitioner a Notice of Intent to Levy and
Notice of Your Right to a Hearing (Levy Notice). Petitioner
received the Levy Notice but did not request a hearing.
Subsequently, respondent and petitioner met for an audit
reconsideration of petitioner’s taxable years 1994 and 1995. On
October 4, 2004, petitioner signed Form 4549, Income Tax
Examination Changes (Form 4549), consenting to the immediate
assessment and collection of tax liabilities for 1994 and 1995.
On February 2, 2005, respondent mailed to petitioner a
notice of Federal tax lien (lien notice) for the taxable years
1(...continued)
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code, as amended.
Page: Previous 1 2 3 4 5 6 Next
Last modified: November 10, 2007