-5-
On March 22, 2004, respondent sent to petitioner a Final
Notice, Notice of Intent to Levy and Notice of Your Right to a
Hearing (Levy Notice). On April 26, 2004, the IRS Service Center
in Kansas City, Missouri, received petitioner’s Request for a
Collection Due Process Hearing (Request) in response to the Levy
Notice on IRS Form 12153, in which petitioner claimed that the
amounts which the IRS asserted were outstanding are in error,
that the Philadelphia Service Center transposed numbers from the
Tax Court decision documents, and has refused to abate the
incorrect amounts.
As stated in the notice of determination, respondent had
previously sent deficiency notices to petitioner for the tax
years 1988 to 1992, inclusive, to which petitioner responded by
filing petitions in this Court. The 1992 case resulted in a
trial and related to an issue not relevant to this case. The
trial also resulted in a holding that the income tax deficiency
and penalties due from petitioner were as detailed below. See
Reese v. Commissioner, T.C. Memo. 1997-346.
The cases for the remaining years, 1988 to 1991, inclusive,
were settled. The decision documents for all 5 years reflect,
among other things, the following:
Income tax IRC Sec. 6651(a) IRC Sec.
Year deficiency addition to tax 6654
1988 $5,101 $445 None
It is stipulated:
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011