Michael E. Nestor - Page 3




                                        - 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.                                                    





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