- 2 -
Petitioner resided in Jacksonville, Florida, at the time he
filed the petition in this case.
Petitioner filed a Federal income tax (tax) return (return)
for his taxable year 1995, which showed $8,125.87 as the tax due
for that year. When petitioner filed his 1995 return, he did not
pay the amount of tax due shown in that return.
On April 28, 2000, respondent issued to petitioner a final
notice of intent to levy with respect to petitioner’s taxable
years 1995, 1996, and 1997 (final notice of intent to levy).
Thereafter, petitioner requested a hearing with the Internal
Revenue Service Appeals Office (Appeals Office) with respect to
that notice.
On October 18, 2000, the Appeals Office held a hearing with
petitioner with respect to the final notice of intent to levy.1
Prior to having been assigned to conduct the Appeals Office
hearing with respect to the final notice of intent to levy, the
Appeals officer who conducted that hearing had had no relation-
ship with petitioner and had not had any involvement with peti-
tioner’s taxable year 1995.
Prior to the Appeals Office hearing, the Appeals officer
1Although the Appeals Office hearing was held with respect
to the final notice of intent to levy, which pertained to peti-
tioner’s taxable years 1995, 1996, and 1997, petitioner peti-
tioned this Court only with respect to his taxable year 1995.
Our discussion hereinafter relates only to petitioner’s taxable
year 1995.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011