Giuseppe Evangelista - Page 4

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                    We’ve finished looking at the information you sent                
               us and we’ve made a decision about your audit reconsid-                
               eration * * *.                                                         
                    We regret to inform you that we decided that we                   
               should not change the original tax amount.  The at-                    
               tached Form 886-A, Explanation of Items, explains how                  
               and why we made our decision.                                          
               Attached to each of respondent’s October 30, 2003 letters              
          was Form 886-A, Explanation of Items, that stated in pertinent              
          part:                                                                       
               Since you did not provide documentation to verify the                  
               deductions being claimed, we are not changing the                      
               previous determination.                                                
               On September 16, 2005, respondent filed notices of Federal             
          tax lien with respect to petitioner’s taxable years 1995, 1996,             
          1997, 1999, and 2000.                                                       
               On September 21, 2005, respondent issued to petitioner a               
          notice of Federal tax lien filing and your right to a hearing               
          (notice of tax lien) with respect to his taxable years 1995,                
          1996, 1997, 1999, and 2000.                                                 
               On October 17, 2005, in response to the notice of tax lien,            
          petitioner, through his authorized representative, mailed to                
          respondent Form 12153, Request for a Collection Due Process                 
          Hearing, and requested a hearing with respondent’s Appeals Office           
          (Appeals Office).                                                           
               On February 14, 2006, a settlement officer with the Appeals            
          Office (settlement officer) held a telephonic Appeals Office                
          hearing with petitioner’s authorized representative.                        





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