James J. and Veronica L. Crisan - Page 2

                                        - 2 -                                         
          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             
               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.                         

          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.                                          

Page:  Previous  1  2  3  4  5  6  7  8  Next 

Last modified: November 10, 2007