- 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 tax
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011