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The sole issue for decision is whether respondent may proceed
with collection of petitioner’s 1997 and 1998 income tax
liabilities.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in California.
The 1997 and 1998 Federal Tax Liens
Petitioner and her former spouse, Gregory Romine (Mr.
Romine), were married during the years in issue. They divorced
in 2003. On September 16, 1998, petitioner and Mr. Romine filed
a joint Federal income tax return for 1997 (the 1997 return). On
the 1997 return, petitioner and Mr. Romine reported tax due of
$254,400 and withholding tax credits of $24,700. No payment
accompanied the return.2
On October 26, 1998, respondent assessed the tax reported on
the 1997 return, interest, and additions to tax. On January 8,
1999, respondent filed a Notice of Federal Tax Lien Filing and
Your Right to a Hearing Under IRC 6320 (NFTL) with the San Diego
2 Petitioner and Mr. Romine paid $65,000 toward their 1997
tax liability on Jan. 19, 1999. A credit for overpayment of tax
from Mr. Romine’s 2002 taxes was also applied against the 1997
liability. Additionally, a payment of $175,964.37 was made
toward the 1997 liability on Nov. 12, 2003.
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