Oliver W. and Harriet S. Williams - Page 8




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               interest in the taxpayers’ property and potentially                    
               collecting the unpaid liability.                                       
                                                                                     
               In response to the notice of determination, petitioners                
          timely filed their petition with this Court on February 9, 2006.            
                                       OPINION                                        
          I.   Notices of Federal Tax Lien                                            
               The record indicates there were two separate notices of                
          Federal tax lien filed with respect to income tax liabilities in            
          1998.  The first notice of Federal tax lien was filed with                  
          respect to the 1998 Form 5329 10-percent additional tax                     
          liability, and the second notice of Federal tax lien was filed              
          with respect to the income tax liability for 1998 other than the            
          10-percent additional tax.  The second notice of Federal tax lien           
          did not include the 1998 Form 5329 10-percent additional income             
          tax liability.                                                              
               Petitioners concede this Court lacks jurisdiction over the             
          unpaid 1998 10-percent additional tax liability because they did            
          not timely submit a request for an administrative hearing with              
          respect to the first notice of Federal tax lien.  See sec.                  
          6320(b)(1); Orum v. Commissioner, 123 T.C. 1, 7-8 (2004), affd.             
          412 F.2d 819 (7th Cir. 2005).                                               
               Petitioners timely submitted a request for an administrative           
          hearing with respect to the second notice of Federal tax lien.              
          See sec. 6320(b)(1).  Although the first and second notices of              
          Federal tax lien include a 1998 income tax liability, they cover            






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