- 2 - believed that there was an abuse of discretion and why respondent should not be allowed to proceed with collection. The sole issue for our consideration is whether respondent’s determination to file NFTLs relating to petitioner’s 1991 tax liability was an abuse of discretion. This case was submitted fully stipulated1 pursuant to Rule 122,2 and the parties’ agreed facts and accompanying exhibits are incorporated herein by this reference. Background At the time his petition was filed, petitioner resided in Hazlehurst, Mississippi. This Court rendered an opinion deciding the merits of petitioner’s 1991 income tax deficiency, Scott v. Commissioner, T.C. Memo. 1997-507, and on June 19, 1998, a decision was entered setting forth the amount of said deficiency. Petitioner appealed to the Court of the Appeals for the Fifth Circuit, and this Court’s decision was affirmed (in an unpublished opinion) on June 3, 1999. See Scott v. Commissioner, 182 F.3d 915 (5th Cir. 1999). 1 This case was submitted fully stipulated at the Trial Session of the Court held at Jackson, Mississippi, on Feb. 6, 2006. This matter was submitted for disposition by order of the Chief Judge to Judge Joel Gerber on Feb. 13, 2007. 2 Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code, as amended and in effect for the period under consideration.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007