- 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