T.C. Memo. 2008-26                                   
                               UNITED STATES TAX COURT                                
                      ROBERT M. SCHARRINGHAUSEN, Petitioner v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 4427-06L.             Filed February 12, 2008.              
                                                                                     
               Richard L. Fahey, for petitioner.                                      
               Karen Sommers, for respondent.                                         
                                 MEMORANDUM OPINION                                   
               HOLMES, Judge:  Robert Scharringhausen files income tax                
          returns but does not always pay the tax due, a habit that finds             
          him owing more than $30,000 for the tax years 2001-03.  The                 
          Commissioner assessed the amount due, and filed a notice of                 
          federal tax lien (NFTL) to protect the government’s interest                
          against the many other creditors Scharringhausen has accumulated.           
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Last modified: March 27, 2008