Dan K. and Paula Shaw, (2010)
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Dan K. and Paula Shaw, (2010)
T.C. Memo. 2010-210
UNITED STATES TAX COURT DAN K. AND PAULA SHAW, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1642-08L. Filed September 27, 2010.Ps filed a petition for judicial review pursuant to sec. 6320, I.R.C., in response to a determination by R that lien action was appropriate.Held: Ps are liable for the addition to tax for failure to pay their tax liability in a timely manner. R's filing of the lien to protect the Government's interest and denial of an installment agreement do not constitute an abuse of discretion. R's determination to proceed with collection action is sustained.Robert E. McKenzie and Kathleen M. Lach, for petitioners. Gorica B. Djuraskovic, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION WHERRY, Judge: This case is before the Court on a petition for judicial review of a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330.1 The issues for decision are (1) whether petitioners are liable for the failure to pay addition to tax imposed by section 6651(a)(2); (2) whether respondent abused his discretion in not agreeing to an installment payment agreement or offer-in-compromise; and (3) whether respondent may proceed with collection by means of a filed tax lien with respect to petitioners' Federal income tax liability for the 2005 tax year.FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts and the accompanying exhibits are hereby incorporated by reference into our findings. Petitioners r...See the full content of this document
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