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of Practice and Procedure.
This proceeding arises from a petition for judicial review
filed in response to a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 (the notice
of determination) sent to petitioners in April 2006. The issue
for decision is whether respondent abused his discretion in
sustaining a proposed levy action against petitioners.
Background
Some of the facts have been stipulated, and they are so
found. The record consists of the stipulation of facts and
supplemental stipulation of facts with attached exhibits,
additional exhibits introduced at trial, and the testimony of
petitioner Douglas Maxfield.
From at least 1995 through the time the petition was filed,
petitioners resided in Bowie, Maryland. All references to
petitioner are to Douglas Maxfield.
Petitioners filed a joint 1999 Federal income tax return.
In March 2003, respondent issued petitioners a notice of
deficiency determining, inter alia, that petitioners were not
entitled to certain claimed deductions. Petitioners did not
petition the Court in response to the notice, and respondent
assessed tax, penalties, and interest against petitioners on
August 4, 2003.
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