Mehdi H. Hajiyani - Page 3

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          alleging that additional information for the year could alter the           
          decision to be entered.  On February 27, 2002, this Court ordered           
          petitioner to file an alternative computation by March 25, 2002.            
          Petitioner failed to file an alternative computation, and on                
          April 26, 2002, a decision was entered determining deficiencies             
          in income tax for the taxable years 1993 and 1994 of $9,228 and             
          $17,369, respectively.                                                      
               On January 4, 2003, respondent sent petitioner a Final                 
          Notice of Intent to Levy and Notice of Your Right to a Hearing              
          (levy notice) for petitioner’s 1993 and 1994 taxable years.  The            
          levy notice reflected an unpaid tax liability (including                    
          interest) of $10,109 for the 1993 taxable year and $33,195 for              
          the 1994 taxable year.                                                      
               On February 2, 2003, respondent received petitioner’s timely           
          Form 12153, Request for a Collection Due Process Hearing                    
          (request), for taxable years 1992, 1993, and 1994.  As a basis              
          for his request, petitioner attached documents showing that he              
          had objected to respondent’s original decision.  Petitioner’s               
          original section 6330 hearing was scheduled for November 19,                
          2003, but it was rescheduled for a later date because of                    
          conflicts.  Petitioner failed to appear for the rescheduled                 
          meeting.  On February 4, 2004, respondent mailed petitioner a               
          Notice of Determination Concerning Collection Action(s) Under               
          Section 6320 and/or 6330 (final notice) determining that the                






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