James R. Kennedy - Page 4




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          through 1988.2  Respondent concedes that the notice required by             
          section 6320(a) was not mailed to petitioner at his last known              
          address and that such notice was therefore invalid.  See sec.               
          6320(a)(2)(C).  In any event, petitioner did not request an                 
          administrative hearing with the Internal Revenue Service Office             
          of Appeals (Appeals Office) in respect of the notice required by            
          section 6320(a), nor did the Appeals Office either conduct an               
          administrative hearing or issue a determination letter regarding            
          the notice required by section 6320(a).                                     
               On or about October 25, 1999, respondent mailed to                     
          petitioner a Final Notice Of Intent To Levy And Notice Of Your              
          Right To A Hearing (notice of intent to levy) concerning                    
          petitioner’s unpaid tax liabilities for the years 1984 through              
          1988.3  The notice of intent to levy was mailed to petitioner at            
          his last known address.  See sec. 6330(a)(2)(C).  Petitioner                
          actually received the notice of intent to levy on October 27,               
          1999, as reflected by the U.S. Postal Service Form 3811, Domestic           
          Return Receipt, that was signed at the time that the notice was             


               2  The notice required by sec. 6320(a) listed petitioner’s             
          tax liabilities as $19,372.79, $715.29, $15,010, $1,618.23, and             
          $2,189.94 for the years 1984, 1985, 1986, 1987, and 1988,                   
          respectively.                                                               
               3  The notice of intent to levy stated that petitioner owed            
          amounts from prior notices, additional penalties, and interest              
          totaling $24,198.16, $886.24, $18,939.59, $2,053.57, and                    
          $2,797.52 for the years 1984, 1985, 1986, 1987, and 1988,                   
          respectively.                                                               





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