Wednesday, November 20, 2019
Following up on my previous posts:
Sullivan v. Commissioner, T.C. Memo. 2019-153 (Nov. 19, 2019):
Petitioner is a clinical professor of law at Harvard Law School and the faculty director of the Harvard Trial Advocacy Workshop and the Harvard Criminal Justice Institute. He did not file a Federal income tax return for 2012 or 2013; IRS records indicate that he likewise failed to file returns for 2005-2011. ...
[P]etitioner’s aggregate outstanding liability for 2012 and 2013 was $1,231,775. The bulk of this assessed liability, for 2013, appears to be attributable to petitioner’s sale during 2013, for $1,865,000, of his former residence at the Newton address.
Petitioner timely filed Form 12153, Request for a Collection Due Process or Equivalent Hearing, listing his address as the Winthrop House address. He checked the box captioned “I cannot pay balance.” Referring to the 2013 liability in particular he stated: “I did not (nor have I ever made) enough money to justify a $1.2M tax.”
On July 3, 2017, the IRS sent petitioner a letter, addressed to his Winthrop House address, acknowledging receipt of his hearing request. The letter advised him that, to be eligible for a collection alternative, he would need to file Federal income tax returns for 2012-2015 and supply a completed Form 433-A, Collection Information Statement for Wage Earners and Self-Employed Individuals. He did not respond to this letter and did not supply any of the requested documents. ...
Finding no abuse of discretion in any respect, we will grant summary judgment for respondent and sustain the proposed collection action.