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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.”
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