Orlun K. Jones - Page 2




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                                     Background                                       
               The record reveals or the parties do not dispute the                   
          following:                                                                  
               Petitioner failed to file Federal income tax returns for               
          1985, 1986, 1987, 1988, 1989, 1990, 1991, and 1992.  By three               
          separate notices of deficiency dated December 8, 1995, respondent           
          determined these deficiencies in and additions to petitioner’s              
          tax:                                                                        
                                             Additions to Tax                         
                                             Sec.           Sec.                      
               Year     Deficiency           6651(a)(1)      6654                     
                  1985        $37,138      $9,285           $2,128                    
                  1986        95,433      23,858     4,619                            
                  1987        105,703      26,426           5,708                     
                  1988        71,986      17,997            4,601                     
                  1989        516,660       129,165         34,941                    
                  1990        717,686       179,422         47,254                    
                  1991        1,023,198       255,800       58,855                    
                  1992        1,307,844       326,961       57,040                    
          Petitioner received the notices of deficiency but did not                   
          petition the Tax Court with respect thereto.                                
               On November 2, 2004, respondent mailed petitioner a Notice             
          of Intent to Levy and Notice of Your Right to a Hearing for                 
          taxable years 1985 through 1992.  This notice indicated that                
          petitioner’s unpaid liability, including interest, totaled $14.8            
          million.  In response to this notice, on November 23, 2004,                 
          petitioner submitted a Form 12153, Request for a Collection Due             
          Process Hearing, challenging the proposed levy on grounds of                
          doubt as to liability and doubt as to collectibility.  On January           







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