Facts you don’t see often in a Tax Court case:  Bruce v. Commissioner, T.C. Memo. 2007-161 (6/21/07):

Petitioner is a long-haul trucker who spends a great deal of time on the road. In 2003, he won more than $1 million dollars from a slot machine in New Jersey. Petitioner timely filed an income tax return and reported the winnings, calculating income tax due of $326,772 offset by withholding of $2,188, but paid nothing beyond the withheld amount. Respondent assessed the reported tax plus additions to tax and interest on May 31, 2004. …

Petitioner, who early in the collections stage had more than $400,000 in net worth and more than $2,000 per month in disposable income, was seeking leniency for not paying taxes on his million dollar gambling winnings. Under these facts and circumstances, it was not an abuse of discretion for respondent’s settlement officer to sustain the filing of the Notice of Federal Tax Lien.