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Federal income taxes that respondent considers to be owed by
petitioner for 1994 through 2000. Following a trial on the
propriety of the lien, we sustain the determination of Appeals.
FINDINGS OF FACT
Most facts were stipulated. We find the facts accordingly.
When the petition was filed herein, petitioner resided in
Chicago, Illinois.
Petitioner received notices of deficiency for 1994 through
2000, and he petitioned this Court with respect thereto. On
July 16, 2003, the Court sustained respondent’s determinations in
the notices of deficiency, as modified by respondent’s
concession. See Ozaki v. Commissioner, T.C. Memo. 2003-213.
Respondent assessed the resulting amounts and mailed to
petitioner a notice and demand for payment of those amounts.
On January 12, 2005, respondent mailed to petitioner a
notice advising petitioner that respondent had filed a Notice of
Federal Tax Lien for the subject years and that petitioner had as
to this filing a right under section 6320 to a hearing with
Appeals. Petitioner requested that hearing on February 4, 2005.
The request essentially alleged that petitioner had a mental
condition and had suffered racial injustice that entitled him to
relief from the lien. On October 18, 2005, Appeals held a
1(...continued)
applicable versions of the Internal Revenue Code.
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