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Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6654
1990 $2,006 $493.00 $129.46
1991 1,834 455.75 104.73
1992 2,201 550.25 -0-
1993 2,021 493.75 -0-
1994 1,954 254.02 -0-
1995 2,899 202.93 -0-
1996 2,951 29.49 156.93
1997 2,996 89.88 -0-
Petitioner received the notices of deficiency for 1992-97,
but he did not file a petition for redetermination of the
deficiencies for 1992-97.
B. The Lien and Levy Proceeding
On October 21, 1999, respondent issued to petitioner a
Notice of Intent to Levy and Notice of Your Right to a Hearing
relating to petitioner’s 1990-97 tax years. On November 17,
1999, petitioner filed a Request for a Collection Due Process
Hearing, Form 12153, for tax years 1990-983 in which he
contended: (1) There was “no valid, underlying assessment” of
taxes; (2) he did not receive the “statutory ‘notice and demand’”
for payment of the taxes at issue; (3) he did not receive a valid
notice of deficiency; and (4) he had no underlying tax liability.
In his request for a hearing, petitioner asked that the Appeals
officer have at the hearing: (1) Verification that “the
3 The record is silent as to why petitioner requested a
hearing with respect to tax year 1998. Because respondent’s
notice of intent to levy did not include 1998, that year is not
in issue here.
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