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Respondent did not issue a notice of deficiency for 1984,
1985, or 1986. Appeals did not consider petitioner's 1984, 1985,
or 1986 tax years. On September 4, 1990, petitioner asked
respondent to explain how respondent concluded that petitioner
owed more tax for 1984.
3. Respondent's Levy of Petitioner's Tax for 1984, 1985, and
1986
On December 10, 1990, respondent issued notices of intent to
levy for 1985 and 1986 to petitioner. Petitioner retained Thomas
Kelly (Kelly) to represent him in December 1990. Petitioner
wrote a letter to respondent around January 7, 1991, inquiring
about petitioner's tax liability for 1984, 1985, and 1986.
Respondent issued a notice of intent to levy for 1984 to
petitioner on January 21, 1991. Respondent's Seattle District
Office wrote to Kelly on February 11, 1991, in response to
petitioner's previous Freedom of Information Act request and
stated that respondent forwarded the request to the Ogden Service
Center.
4. Abatement of the Overassessment
Kelly wrote to respondent to request a copy of the notice of
deficiency for 1984 and to explain how respondent made the 1984
assessment against petitioner. On February 13, 1991, Kelly wrote
to respondent's collection branch in Seattle, Washington, to
state that respondent improperly assessed petitioner's tax for
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