- 2 - Background Thomas Lou Harris resided in Mount Vernon, Washington, when he filed his petition. The assessments relate to his 1987, 1988, 1989, 1990, 1991, 1992, and 1993 Federal income tax liabilities (i.e., years in which petitioner did not file returns). On September 11, 1998, respondent issued petitioner notices of deficiency relating to the years in issue. Petitioner received, but did not seek redetermination of, the notices of deficiency. On October 13, 1999, respondent sent petitioner a Notice of Intent to Levy and Notice of Your Right to a Hearing. On October 27, 1999, petitioner filed a request for a Collection Due Process Hearing (i.e., Form 12153) stating that “No summary assessment has been provided as requested.” In a letter dated June 29, 2000, respondent’s Appeals officer scheduled petitioner’s hearing for July 14, 2000, at 8:30 a.m. and provided petitioner with the option of a face-to-face or a telephone hearing. The letter also stated that petitioner had been provided with a copy of computer transcripts that identified the record of assessment and included data “identifying the tax periods, the taxpayer, taxable activities, list of tax owed as [it] appears on [the] record of assessment, and certifying officer.” Petitioner did not appear at the hearing or call the Appeals officer.Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011