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respondent assessed the deficiency, together with the accuracy-
related penalty and statutory interest. On that same day,
respondent sent petitioner and his wife a statutory notice of
balance due, informing them that they had a liability for 1998
and requesting that they pay that liability. Petitioner and his
wife failed to pay the amount owing.
D. Respondent’s Final Notices and Petitioner’s Responses
On November 16, 2000, respondent mailed to petitioner and
his wife a Final Notice--Notice of Intent to Levy and Notice of
Your Right to a Hearing in respect of their outstanding tax
liabilities for 1997 and 1998 (but not 1995). Thereafter, on
December 12, 2000, respondent received from petitioner a Form
12153, Request for a Collection Due Process Hearing. Petitioner
attached to the Form 12153 a 2-page typewritten statement and a
copy of various Treasury regulations.
On April 28, 2001, respondent mailed to petitioner and his
wife a Final Notice--Notice of Intent to Levy and Notice of Your
Right to a Hearing (the final notice) in respect of their
outstanding tax liabilities for 1995, 1997, and 1998. The final
notice stated that the total amount then due from petitioner and
his wife was as follows:
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