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2002 (years at issue).1 Pursuant to section 6330(d), petitioners
seek review of respondent’s determination. The issues for
decision are: (1) Whether petitioners have a right to a judicial
review of respondent’s notice of determination sustaining a
Federal tax lien which covers the same tax year as a previous
Federal tax lien (in which petitioners failed to request an
administrative hearing) but concerns a different type of unpaid
tax for that year; and (2) whether petitioners are entitled to
any relief from respondent’s determination that collection may
proceed.
FINDINGS OF FACT
A. Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and exhibits are incorporated herein by
this reference. Petitioners resided in Ossining, New York, when
they filed this petition. Petitioners are Oliver W. Williams, an
attorney, and his wife, Harriet S. Williams, a psychologist.
Petitioners failed to pay Federal income tax liabilities shown on
their returns for the years at issue.
B. Petitioners’ Installment Agreement
In June 1997, petitioners and respondent entered into an
installment agreement in which petitioners agreed to pay their
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended. Amounts are rounded to
the nearest dollar.
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Last modified: November 10, 2007