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October 8, 2004. The case at docket No. 14984-05L arises from a
petition filed in response to a Determination Letter Concerning
Collection Action(s) Under Section 6320 and/or 6330 (notice of
determination) issued on August 2, 2005. Mrs. Hunter is not a
party to the case at docket No. 14984-05L.
The first issue for decision is whether John E. Hunter, II,
and Alma E. Hunter (the Hunters) are liable for $976 of
alternative minimum tax (AMT) for the taxable year 2002. The
remaining issues for decision are whether the Hunters are
entitled to a credit against their tax liability for 2002 and
whether Mr. Hunter was denied an adequate opportunity for an
administrative hearing regarding a notice of Federal tax lien
filing and a proposed levy action against him.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated as our findings by this reference. The
record consists of the stipulation of facts with attached
exhibits for each case, additional exhibits introduced at trial,
and the testimony of Mr. Hunter. The Hunters are married and
resided in Ann Arbor, Michigan, at all relevant times.
Each case before us involves the taxable year 2002. Because
a primary source of dispute concerns the taxable year 2001,
however, we begin by describing the facts relevant to that year.
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