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section 6330(d), petitioners seek review of respondent’s
determination. The issue for decision is whether respondent
abused his discretion by sustaining the filing of a Federal tax
lien.
Background
The parties submitted this case fully stipulated pursuant to
Rule 122. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Warren, Ohio, when they filed their petition.
Petitioners filed their Forms 1040, U.S. Individual Income
Tax Return, for 2001 and 2002 on October 20 and December 1, 2003,
respectively, and the amounts reported as due for those years
were assessed. A notice and demand for payment was mailed to
petitioners within 60 days of each assessment as required under
section 6303.
On November 4, 2004, Letter 1058, Final Notice of Intent to
Levy and Your Right to a Hearing (notice of levy), was mailed to
petitioners with respect to the years at issue. The notice of
levy indicated that a Federal tax lien could be filed at any
time. Petitioners acknowledged receipt of the notice of levy on
November 23, 2004, but failed to request a hearing.
1(...continued)
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure. Amounts
are rounded to the nearest dollar.
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