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determination by filing a petition for redetermination with this
Court, petitioner chose not to do so.
On October 30, 2000, respondent entered assessments against
petitioner for the deficiency and accuracy-related penalty
determined in the notice of deficiency for 1997 described above.
Respondent also entered an assessment against petitioner for
statutory interest. On October 30, 2000, and December 4, 2000,
respondent issued to petitioner notices of balance due informing
petitioner that he owed tax for 1997 and requesting that he pay
such amount. Petitioner failed to pay the amount owing.
On February 22, 2001, respondent mailed to petitioner a
Final Notice-–Notice of Intent to Levy and Notice of Your Right
to a Hearing with regard to his tax liability for 1997. On
February 24, 2001, petitioner filed with respondent a Form 12153,
Request for a Collection Due Process Hearing. Petitioner’s
request included a challenge to the validity of the assessments
and assertions that respondent failed to serve petitioner with a
valid notice and demand for payment or a valid notice of
deficiency. Petitioner also requested verification from the
Secretary that all applicable laws and administrative procedures
were followed with regard to the assessment and collection of the
tax liability in question.
On November 13, 2001, Appeals Officer Douglas DeSoto
conducted an Appeals Office hearing in this matter that
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Last modified: May 25, 2011