John R. Peacock - Page 2

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          of deficiency.  On May 23, 1997, respondent sent petitioner a               
          second notice, which corrected a typographical error in the April           
          18, 1997, notice.  Petitioner did not file a petition with the              
          Court to challenge either notice.  On October 13, 1997,                     
          respondent assessed a $42,859 deficiency and, pursuant to                   
          sections 66511 and 6654, a $4,027.50 addition to tax and a                  
          $676.92 addition to tax, respectively.                                      
               On December 31, 1997, respondent sent a Form 668-W(c),                 
          Notice of Levy on Wages, Salary, and Other Income (notice of                
          levy), to petitioner’s employer, United Airlines (United).  The             
          notice of levy required United to relinquish a portion of                   
          petitioner’s pay to satisfy his 1994 tax liability.                         
               Respondent, on February 16, 2001, sent petitioner a Final              
          Notice--Notice of Intent to Levy and Notice of Your Right to a              
          Hearing, relating to his 1994 tax liability.  On March 14, 2001,            
          petitioner sent respondent Form 12153, Request for a Collection             
          Due Process Hearing, in which petitioner alleged that the tax               
          liability had been fully paid.  On August 10, 2001, the Appeals             
          officer held a conference with petitioner.  The Appeals officer             
          reviewed transcripts of petitioner’s 1994 income tax account and            
          payroll records.  The payroll records indicated that between                
          October 20, 1997, and November 17, 1998, United, pursuant to an             


               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code in effect for the year in issue.                  





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