Curtis J.L. McIntosh - Page 6

                                        - 6 -                                         
               On March 9, 2000, petitioner attended an Appeals Office                
          hearing in Cincinnati, Ohio, conducted by Appeals Officer William           
          C. Roll.  On July 21, 2000, the Appeals Office mailed to                    
          petitioner a Notice of Determination Concerning Collection                  
          Action(s) Under Section 6320 and/or 6330 (notice of                         
          determination).  The notice of determination states in pertinent            
          part:                                                                       
               The assessments for 1986 are invalid, and no collection                
               action will be enforced.                                               
               For 1990, the assessments are valid.  In your appeal,                  
               you did not raise any alternative collection method to                 
               enforce collection, and the proposed levy should be                    
               enforced.                                                              
          An attachment to the notice of determination states in pertinent            
          part:                                                                       
               A valid notice of deficiency [for 1990] was issued, and                
               assessments were made in accordance with legal and                     
               procedural requirements.  The deficiency notice was                    
               mailed to your last known address, at the time the                     
               notice was mailed.  Your failure to file current                       
               returns prevented an update of your address, so that                   
               you failed to receive notices of demand for payment.                   
               Your failure to receive the notices mailed to your last                
               known address does not invalidate the assessments.  The                
               legal and procedural requirements for 1990 have been                   
               met.                                                                   
                         *    *    *    *    *    *    *                              
               It is determined that a deficiency notice for 1990 was                 
               mailed timely to your last known address.  Your failure                
               to file any tax return after 1989, and failure to                      
               cooperate in acknowledging your new address,                           
               contributed to the lack of your current address being                  
               in the files of the Internal Revenue Service.  Because                 
               notices were issued to your last known address as of                   






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011