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otherwise indicated, all section references are to the Internal
Revenue Code, as amended.
Background
All of the facts have been stipulated, and the stipulated
facts are incorporated as our findings by this reference.
Petitioners resided in California at the time that their petition
was filed. Petitioner Michael D. Cornwell (petitioner) is and
for many years has been employed as a legal assistant at a law
firm.
For tax years 1994 through 1996, petitioner filed
Forms 1040, U.S. Individual Income Tax Return, but failed to pay
the amounts shown as tax due on those returns. For 1997 through
2002, petitioners filed joint Federal income tax returns but did
not pay the balances due on those returns.
On October 20, 2003, the Internal Revenue Service (IRS) sent
to petitioner a Notice of Federal Tax Lien Filing and Your Right
to a Hearing Under IRC 6320, advising petitioner that a Notice of
Federal Tax Lien had been filed with respect to his unpaid
liabilities for 1994, 1995, and 1996. (The parties’ stipulation
of facts and respondent’s brief erroneously set forth the date as
October 20, 2004.)
On October 24, 2003, the IRS sent to petitioners a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320, advising petitioners that a Notice of Federal Tax Lien had
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