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(waiver), on July 15, 2005. Tax and interest were assessed
thereafter.
On October 13, 2005, respondent mailed to petitioner a
Notice of Federal Tax Lien Filing and Your Right to a Hearing
Under IRC 6320 showing an “Amount Owed” of $11,525.97.
Petitioner responded by mailing a check to respondent for
$11,525.97 on or about October 20, 2005.
The issue of the underpayments of tax having been resolved,
respondent mailed to petitioner on December 13, 2005, the notice
of deficiency from which petitioner appealed to this Court. In
the notice, respondent determined civil fraud penalties under
section 6663(a) for 1992, 1993, and 1994, in the amounts of
$1,974, $3,206.25, and $2,258.25, respectively.
Petitioner contends that because he paid the “Amount Owed”
listed on the Notice of Federal Tax Lien Filing, he should not
have to pay any additional amount; he seeks to have us direct the
IRS to withdraw the lien. He also contends that it would be
unfair to require him to pay any amount in addition to the
underpayments of tax because paying such additional amounts would
deprive him of all assets; he thus seeks relief from the civil
fraud penalties and statutory interest. We address petitioner’s
contentions in turn below.
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