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the taxes owed. Respondent assessed tax liabilities against
petitioner for these taxable years pursuant to the Federal income
tax returns petitioner filed.2
On February 27, 1999, respondent mailed to petitioner a
letter captioned “Final Notice--Notice of Intent to Levy and
Notice of Your Right to a Hearing” for unpaid tax liabilities for
taxable years 1989, 1990, 1991, and 1992. Also on February 27,
1999, respondent’s agent mailed to petitioner and to petitioner’s
former wife, Linda A. Boyd (Linda), a letter captioned “Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing” for unpaid tax liabilities for taxable years 1993, 1996,
and 1997. Each letter was accompanied by a Form 12153, Request
for a Collection Due Process Hearing (Form 12153), which a
taxpayer may use to request a section 6330 hearing.
On March 20, 1999, respondent received from petitioner a
completed Form 12153, submitted on behalf of petitioner and
2 The respective assessment dates of petitioner’s income tax
liability for the subject years were as follows:
Assessment
Year Date
1989 5/21/90
1990 5/20/91
1991 8/03/92
1992 7/12/93
1993 6/06/94
1996 6/02/97
1997 5/25/98
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Last modified: May 25, 2011