Terry Hiram Pierson - Page 3




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                                     Background                                       
               On October 6, 1995, respondent issued a notice of deficiency           
          to petitioner determining a deficiency of $5,944 in his Federal             
          income tax for 1988, as well as an addition to tax pursuant to              
          section 6651(a)(1) in the amount of $736 and an addition to tax             
          pursuant to section 6654(a) in the amount of $166.  Petitioner              
          did not file a petition with the Court contesting the notice of             
          deficiency within the 90-day period prescribed in section                   
          6213(a).                                                                    
               The notice of deficiency for 1988 was mailed to petitioner             
          at 7690 Knox Court, Westminster, Colorado 80030, the same address           
          that petitioner used in filing the petition herein.  Petitioner             
          does not allege that he did not receive the notice of deficiency,           
          and respondent has no record that the notice was returned by the            
          U.S. Postal Service to respondent as undelivered.                           
               On January 24, 2000, respondent mailed a final notice of               
          intent to levy to petitioner.  See sec. 6331.  The notice stated            
          that petitioner owed tax and additional amounts totaling                    
          $8,309.06 for the taxable year 1988 and that respondent was                 
          preparing to collect this amount.  The notice also stated that              
          petitioner would be given 30 days to request an Appeals Office              
          hearing.                                                                    
               Petitioner requested a hearing with respondent's Appeals               
          Office.  On July 12, 2000, the Appeals Office issued a Notice of            






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