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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.
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Last modified: May 25, 2011