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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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Last modified: May 25, 2011