- 2 - indicated, subsequent section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure. Petitioner filed the petition in this case in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The only issue before the Court is whether respondent abused his discretion in sustaining the decision to file a Federal tax lien with respect to petitioner’s income tax liabilities for the taxable years 1998, 1999, 2000, 2001, and 2002 (years in issue).1 Background Petitioner resided in California when he filed the petition in this case. The parties did not file a stipulation of facts. Petitioner filed delinquent Federal income tax returns for the years in issue. Each return reported tax owed, but payment was not included with the returns. Respondent selected petitioner’s 1999 Federal income tax return for examination and determined a deficiency for that year. Respondent issued a notice of deficiency, and petitioner timely petitioned this Court 1 Respondent moved for summary judgment pursuant to Rule 121. Having called this case for trial and taken petitioner’s testimony, we will deny respondent’s motion for summary judgment and decide this case on the merits. Petitioner also made several oral motions at trial. For reasons discussed infra pp. 18-19, we will deny petitioner’s motions.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008