Sam E. Scott - Page 2




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          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          unpublished opinion) on June 3, 1999.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.                                  





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