William A. Hoffman, Jr. - Page 2




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          respondent's Notice of Determination Concerning Collection                  
          Actions Under Section 6320 and/or 6330.                                     
               On May 23, 1997, respondent issued a notice of deficiency to           
          petitioner determining a deficiency in, additions to, and                   
          penalties on petitioner's 1994 Federal income tax.  Petitioner              
          received the notice of deficiency and responded to respondent by            
          a letter dated June 8, 1997.  Petitioner failed to petition this            
          Court within the time required by section 6213 with respect to              
          the notice of deficiency.                                                   
               Subsequently, on April 7, 1999, respondent sent petitioner a           
          Final Notice of Intent to Levy pursuant to section 6330.  The               
          notice stated that petitioner owed taxes, penalties, and interest           
          totaling $7,729.59 for the 1994 taxable year and that respondent            
          was preparing to collect that amount by levy.  The notice stated            
          that petitioner could request a "Collection Due Process Hearing"            
          with respondent's Appeals Office.                                           
               On April 21, 1999, respondent received from petitioner a               
          request for a collection due process hearing.  On July 14, 1999,            
          petitioner met with Appeals Officer Fred McMullen of the Southern           
          California Appeals Division.  At that meeting, petitioner                   
          declined to discuss collection alternatives or any facts                    
          concerning his tax liability and chose instead to present                   
          frivolous arguments.  Consequently, Appeals Officer McMullen                








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