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Eighth Circuit (Court of Appeals for the Eighth Circuit) with
respect to the Tax Court decision. On January 16, 2002, that
Court affirmed the Tax Court decision. Hollen v. Commissioner,
25 Fed. Appx. 484 (8th Cir. 2002).
On June 5, 2001, respondent assessed tax of $55,550, addi-
tions to tax under sections 6653(a)1 and 6661 of $67,978.11 and
$13,887.50, respectively, and interest as provided by law for
petitioners’ taxable year 1988. On February 25, 2002, respondent
assessed additional interest as provided by law. (We shall refer
to any unpaid assessed amounts with respect to petitioners’
taxable year 1988, as well as interest as provided by law accrued
after February 25, 2002, as petitioners’ unpaid 1988 liability.)
Respondent issued to petitioners the notice and demand for
payment required by section 6303(a) with respect to petitioners’
unpaid 1988 liability.
On December 15, 2004, respondent issued to petitioners a
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to their taxable year
1988.
On December 28, 2004, respondent filed a notice of Federal
tax lien (tax lien filing) with respect to petitioners for their
taxable year 1988.
1All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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