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On December 21, 1999, petitioner and his wife wrote a second
letter to the Court stating that they did not intend to file a
petition for redetermination with the Court. On December 29,
1999, the Court entered an Order of Dismissal for Lack of
Jurisdiction in docket No. 18537-99.
On June 5, 2000, respondent assessed the deficiencies and
additions to tax for 1995 and 1996 determined in the notice of
deficiency dated October 7, 1999, as well as statutory interest.
On June 5, 2000, respondent sent petitioner notices of balance
due, informing petitioner that he had tax liabilities for 1995
and 1996 and requesting that he pay them. Petitioner failed to
do so.
On July 10, 2000, respondent entered an additional
assessment against petitioner in the amount of $869.19 for the
taxable year 1996 reflecting an addition to tax under section
6651(a)(2) for failure to pay tax shown on a return. On that
same date, respondent sent petitioner a notice of balance due,
informing petitioner that he had a tax liability for 1996 and
requesting that he pay it. Petitioner failed to do so.
C. Respondent’s Final Notice and Petitioner’s Response
On August 18, 2000, respondent sent petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 in respect of petitioner’s outstanding liabilities for 1995
and 1996. On September 8, 2000, petitioner submitted to
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