- 3 - 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 not for 1990 or 1991. 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 Form 12153, Request for a Collection Due Process Hearing, for tax years 1990-982 and contended that: (1) There was no valid 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) the amount of the underlying tax liability was incorrect. C. The Section 6330 Hearing and Respondent’s Notice of Determination On December 28, 1999, respondent’s Appeals Office conducted a hearing in petitioner’s case for tax years 1990-97. 2 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 was not at issue at the hearing.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011