- 2 - Federal Tax Lien, filed on or about October 21, 2003, is an appropriate collection device with respect to petitioner’s outstanding Federal income tax liabilities for the years 1996 through 1999, inclusive, which liabilities, including additions to tax and interest, at the time totaled more than $56,000 (petitioner’s outstanding tax liabilities). The issue for decision is whether respondent abused his discretion:2 (1) By refusing to release or withdraw the above- referenced Notice of Federal Tax Lien, and/or (2) by rejecting petitioner’s proposed collection alternative. Background The absence of a stipulation of facts notwithstanding, see Rule 91, the relevant facts in this case are relatively straightforward and easily summarized. Petitioner’s outstanding tax liabilities arise from amounts reported on Federal income tax returns. As best as can be determined from the record, each return was filed late, and the unpaid tax liability shown on each return is attributable 2 In his request for an administrative hearing, petitioner alleged that the “IRS assigns arbitrary amounts due without providing any basis for its outstanding amount determinations”. Similarly, in the petition, petitioner alleges that “lien collection amounts are arbitrary”. Because nothing was submitted supporting those allegations during either the administrative hearing or the trial, we do not consider petitioner to have challenged the existence or the amount of his outstanding tax liabilities. Consequently, we review respondent’s collection action for abuse of discretion. Sego v. Commissioner, 114 T.C. 604, 610 (2000).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007