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12153, Request for Collection Due Process Hearing. In his Form
12153, petitioner contested only the tax liability.
On January 29, 2004, respondent mailed to petitioner a
letter advising him that his Form 12153 had been received and
that his request for a hearing was being processed. Petitioner
was further advised in this letter that he had not filed income
tax returns for the taxable years 1998, 1999, 2000, 2001, and
2002, and he was instructed to file said returns by February 12,
2004. He was further instructed that if he failed to file the
returns, the matter would be forwarded to respondent’s Appeals
Office for consideration of his request for a hearing.
Petitioner has acknowledged that he received the January 29,
2004, letter. Petitioner failed to file, as of the date of
trial, any income tax returns for the taxable years 1998 through
2002.
In an April 14, 2004, letter, the Appeals officer advised
petitioner to contact her and schedule a hearing. She also
advised petitioner that he should provide her with all
information he had in support of his position that his underlying
tax liability was in error, and that she could not offer him a
collection alternative in satisfaction of his tax liability for
1999 because he continued to fail to file his income tax returns.
On May 24, 2004, petitioner mailed to the Appeals officer a
copy of a Form 1099-MISC, Miscellaneous Income, issued to
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