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levy is the appropriate collection action which
balances the need for efficient collection of the tax
with any concerns you may have as to the intrusiveness
of the action.
In response to the Notice, petitioner filed his petition in
this case. In his petition, petitioner alleges that the amounts
of the underlying tax liability and the years are:
Year Amount
1993 $8,600.09
1994 3,961.31
1995 801.89
1996 901.10
Total 14,264.39
Petitioner claimed a credit “from a prior year overpayment
to be used to offset, in part if not in full, the liabilities in
question.”
In his answer, respondent denied that the levy determination
relates to a tax liability for 1996, and asserts that the levy
determination relates to petitioner’s unpaid income tax liability
for 1997 in the amount of $901.10, including interest and
penalties through March 8, 2000. Petitioner does not challenge
this assertion.
OPINION
I. Standard of Review
Respondent did not send a notice of deficiency to
petitioner. Petitioner did not otherwise have an opportunity to
dispute his tax liability for 1993, 1994, 1995, or 1997. Thus,
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Last modified: May 25, 2011