McCorkle v. Comm'r
United States Tax Court
R's Appeals Office determined that R was warranted in filing a notice of Federal tax lien (NFTL) against P with respect to his 1996 Federal income tax liability. P assigns error on the grounds that R erroneously refunded his $ 2 million remittance for 1996 to the U.S. Marshals Service pursuant to a forfeiture order issued under 18 U.S.C. sec. 982 (2000) by the District Court in an unrelated, non-tax criminal case.
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R's Appeals Office determined that R was warranted in filing a notice of Federal tax lien (NFTL) against P with respect to his 1996 Federal income tax liability. P assigns error on the grounds that R erroneously refunded his $ 2 million remittance for 1996 to the U.S. Marshals Service pursuant to a forfeiture order issued under 18 U.S.C. sec. 982 (2000) by the District Court in an unrelated, non-tax criminal case. R and P have both moved for summary judgment. 1. Held: R was dutybound to comply with the forfeiture order, which is not subject to collateral attack in this court. 2. Held,…
1Opinion of the Court
OPINION
HALPERN, Judge:
This case is before the Court to review a determination made by respondent’s Appeals Office (Appeals) that respondent was warranted in filing a notice of Federal tax lien (the notice of Federal tax lien or nftl) against petitioner with respect to his Federal income tax liability for 1996 (1996 tax liability). We review that determination pursuant to sections 6320(c) and 6330(d)(1).1 Petitioner assigns error to Appeals’ determination on the grounds that Appeals erred in determining that a $2 million remittance made by petitioner to the Internal Revenue Service (irs) on or…
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