- 4 - Respondent’s records reflect that the notice of deficiency was not returned undelivered to respondent by the Postal Service. Petitioner has not denied that he received the notice of deficiency. C. Assessment of Petitioner’s Liability Petitioner did not file a petition for redetermination with the Court challenging the notice of deficiency. Accordingly, on May 22, 1995, respondent assessed the determined deficiency and additions to tax, as well as statutory interest. On that same day, respondent sent petitioner a notice and demand for payment, informing petitioner that he had a liability for 1992 and requesting that he pay it. Petitioner failed to do so. On October 9, 2000, respondent sent petitioner a second collection notice for 1992. Once again, petitioner failed to pay the amount owing. D. Respondent’s Final Notice and Petitioner’s Response On November 10, 2000, respondent sent petitioner a Final Notice-–Notice of Intent to Levy and Notice of Your Right to a Hearing (the Final Notice). The Final Notice was issued in respect of petitioner’s outstanding liability for 1992. On November 29, 2000, petitioner submitted to respondent a Form 12153, Request for a Collection Due Process Hearing. Petitioner’s request stated that the period of limitations had expired with respect to the assessment of petitioner’s taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011