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(notice of determination).2 Pursuant to section 6330(d),
petitioner seeks our review of respondent’s determination
upholding the proposed use of a levy to collect petitioner’s
income tax liabilities for tax years 1997, 1998, 1999, and 2000.
The issue for decision is whether respondent’s proposed levy
actions may proceed.
Background
These consolidated cases were submitted fully stipulated
pursuant to Rule 122. The case at docket No. 7163-06L pertains
to tax years 1997 and 1998. The case at docket No. 7162-06L
pertains to tax years 1999 and 2000. The stipulations of fact
and the attached exhibits are incorporated herein by this
reference. At the time he filed the petitions, petitioner
resided in Chicago, Illinois.
Petitioner, who was born in 1946, is an attorney who
practiced law with various Chicago law firms at different times
during the years at issue. Petitioner filed income tax returns
for the years at issue as follows:
Self-Em-
Date Return Adjusted Income ployment
Due (After Date Gross Income Tax per Tax per
Year Extensions) Return Filed per Return Return Return
1997 Oct. 15, 1998 July 25, 2001 $163,286 $25,692 $15,431
1998 Oct. 15, 1999 Aug. 15, 2001 213,864 40,918 16,684
2Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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Last modified: November 10, 2007