- 3 - amount owed (including unpaid taxes, penalties, and interest) for 1987, 1988, 1989, and 1992 as of the date of the collection notice as $1,522,588.25. On March 17, 2000, petitioner sent respondent a Request for a Collection Due Process Hearing for 1987, 1988, 1989, and 1992 (hearing request). Appeals Officer Keith Fessenden was assigned to petitioner’s case. Appeals Officer Fessenden sent petitioner two letters scheduling a telephone hearing with petitioner. Petitioner sent Appeals Officer Fessenden a letter stating that he (petitioner) did not have a phone. In this letter, petitioner did not raise any collection alternatives; he raised frivolous and groundless arguments regarding his underlying tax liabilities. On June 8, 2000, respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) for 1987, 1988, 1989, and 1992 concluding that respondent could proceed with the proposed collection action because “the proposed collection action balances the need for efficient collection of taxes with * * * [petitioner’s] legitimate concern that any collection action be no more intrusive than necessary.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011