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FINDINGS OF FACT
Respondent assessed petitioner’s Federal income tax
liability relating to 1977 through 1992, 1994, and 1997 as
follows:
Tax Year Tax Liability Assessment Date
1977-84 $121,359 Oct. 2, 1995
1985 5,741 Oct. 10, 1994
1986 4,201 Oct. 17, 1994
1987 4,061 Oct. 24, 1994
1988 4,414 Oct. 31, 1994
1989-90 13,092 Nov. 7, 1994
1991 5,558 Sept. 26, 1994
1992 1,324 Sept. 19, 1994
1994 10,106 Oct. 23, 1995
1997 4,663 Aug. 30, 1999
Respondent also assessed interest, various penalties, and
additions to tax relating to the years in issue.
On February 1, 2000, respondent sent petitioner Notices of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 relating to 1977 through 1992, 1994, and 1997. On February
21, 2000, petitioner filed a Form 12153, Request for a Collection
Due Process Hearing.
On December 11, 2000, petitioner attended the Collection Due
Process Hearing (the hearing), during which petitioner and
respondent discussed the assessments, various collection
alternatives, and whether petitioner would submit so called
“corrected returns” relating to 1977 through 1984 (i.e., the tax
years for which respondent prepared substitute returns). In
addition, respondent asked petitioner to submit a financial
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Last modified: May 25, 2011