PURSUANT TO INTERNAL REVENUE CODE
SECTION 7463(b),THIS OPINION MAY NOT
BE TREATED AS PRECEDENT FOR ANY
T.C. Summary Opinion 2006-63
UNITED STATES TAX COURT
JAMES WELDON AARON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14787-04S. Filed April 24, 2006.
James Weldon Aaron, pro se.
Monica J. Miller, for respondent.
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of sections 6330(d) and 7463 of the
Internal Revenue Code in effect when the petition was filed. The
decision to be entered is not reviewable by any other court, and
this opinion should not be cited as authority. Unless otherwise
indicated, all subsequent section references are to the Internal
Revenue Code in effect at relevant times.
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1 The OIC also included the taxable years 1992 and 1993 but
did not include the taxable year 2002. The taxable years 1992
and 1993 are not before the Court.
This proceeding arises from a petition for judicial review
filed in response to a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 (notice of
determination) sent to petitioner on July 12, 2004. The issue
for decision is whether respondent abused his discretion in
sustaining a notice of Federal tax lien filed against petitioner.
Some of the facts have been stipulated, and they are so
found. The record consists of the stipulation of facts with
attached exhibits, an additional exhibit introduced at trial, and
the testimony of petitioner. At the time of filing the petition,
petitioner resided in Sebring, Florida.
Respondent made assessments against petitioner for income
taxes, related penalties, and interest for the taxable years
1994, 1995, 1996, and 2002. Respondent sent a notice and demand
for payment for each of the years at issue, but petitioner failed
to remit payment.
In February 2003, petitioner submitted an offer-in-
compromise (OIC), in w