- 2 - 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 McMullenPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011