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heart blockage issues, high blood pressure, a malignant tumor,
which was under treatment, and motor problems with his left leg
requiring use of a walker.
Petitioner also outlined his financial condition in the
memorandum explaining that his only steady income was a monthly
$1,727 Social Security payment and that his professional income
from law practice was greatly reduced. He listed monthly
expenses totaling $5,254.81 and various outstanding liabilities,
including credit card debt, bank loans, and mortgages totaling
approximately $422,000. His outstanding 1991 income tax
liability was not included in the $422,000 amount. Petitioner
reflected assets exceeding liabilities by an amount less than
$100,000, after considering his tax liabilities. He proposed a
plan to refinance his assets in order to make an offer-in-
compromise and to delay filing of the NFTLs, which petitioner
believed would “destroy” his credit. Alternatively, he stated
that if respondent filed the NFTLs and pursued collection,
petitioner would be “driven” into bankruptcy.
Thereafter, respondent, by certified mail, sent petitioner
Notices of Federal Tax Lien Filing and Your Right To a Hearing
Under IRC 6320, dated August 4 and August 10, 2004, which is also
denominated as a “Letter 3172", along with three Notices of
Federal Tax Lien, all of which concerned petitioner’s 1991 tax
liability. The NFTLs were filed on August 6, 2004. On or about
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