- 2 - by levy Federal income taxes owing by petitioner for the year 1990 should proceed. That determination was preceded by respondent's issuance to petitioner of a notice of intent to levy and of petitioner's right to a hearing in connection with an assessed balance of income taxes for 1990 of $486.77 and statutory additions of $2,142.20. Some of the facts were stipulated. Those facts, with the exhibits annexed thereto, are so found and are made part hereof. At the time the petition for review was filed, petitioner was a legal resident of Italy, Texas. A notice of deficiency was issued to petitioner for 1990, and respondent's determinations in that notice were never judicially challenged or litigated by petitioner. Petitioner was, in due course, assessed for the amounts determined in the notice of deficiency.2 In his petition for review, petitioner alleges that he had previously entered into an agreement with a representative of respondent to the effect that, if he made the equivalent of monthly payments over a 12-month period totaling $1,296, his 2 The notice of deficiency was not offered into evidence at trial. It appears that petitioner had not filed a tax return for 1990; however, after the notice of deficiency was issued, petitioner filed a return that mirrored the determinations in the notice of deficiency. In his petition and at the hearing, petitioner did not allege or contend that he never received the notice of deficiency.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011