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Background
At the time the petition was filed, petitioner resided in
San Francisco, California. The amounts for which petitioner
seeks relief relate to his 1994 tax year.
The Internal Revenue Service (IRS) assessed an income tax
deficiency (along with penalties and interest) and three section
6702 frivolous return penalties (and related interest) with
regard to petitioner’s 1994 tax return. On February 4, 1999,
after previously collecting and applying $1,019 to the
outstanding liability related to the section 6702 frivolous
return penalties and related interest (prior collection
activities), respondent issued a Notice of Intent to Levy and
Notice of Your Right to a Hearing (levy notice) to petitioner
with regard to the outstanding balance of the income tax
deficiency (and related penalties and interest) and the section
6702 frivolous return penalties (and related interest). See sec.
6330(a). In the levy notice, among other items, the IRS asserted
that petitioner had an outstanding balance of $500 for the
section 6702 frivolous return penalties and $59 for interest
related to those penalties. The outstanding balance for the 1994
tax year as presented in the levy notice is reproduced below:
Form Tax Unpaid Amount Additional
Number Period from Prior Notices Penalty & Interest Amount You Owe
1040 12/31/94 $1,227.91 $498.85 $1,726.76
civ pen 12/31/94 500.00 58.56 558.56
Pursuant to section 6330(b), petitioner requested a hearing
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Last modified: May 25, 2011