Jose A. Perez - Page 4

                                        - 4 -                                         
          covering the years 1984 through 1987, which listed as the                   
          taxpayer both himself and his spouse.  In an addendum to the Form           
          12153, petitioner alleged four errors with respect to                       
          respondent’s proposed collection actions:  (1) That he had not              
          received Forms 23C for the years 1984 through 1987; (2) that he             
          had not received notices of deficiency for the years 1984 through           
          1987; (3) that the Form 900 executed by him was invalid; and (4)            
          that the IRS had failed to publish pertinent data concerning Form           
          900 in the Federal Register.  Petitioner did not raise any                  
          spousal defenses or offer any collection alternatives.                      
          Petitioner, but not his spouse, signed the Form 12153.                      
               Petitioner’s hearing was conducted by an Appeals officer of            
          respondent.  A face-to-face meeting between petitioner and the              
          Appeals officer was held.  At the hearing, petitioner raised an             
          additional issue to the effect that a levy served on his employer           
          on or about March 18, 1997, was invalid due to lack of proper               
               During the meeting with petitioner, the Appeals officer                
          provided petitioner with a MFTRA-X version of his transcript of             
          account.  Relying on the codes contained in the MFTRA-X                     
          transcript, the Appeals officer determined that the respondent              
          had properly assessed petitioner’s tax liabilities for 1984,                
          1985, 1986, and 1987.                                                       

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011