- 2 - against him. The case originated with respondent's issuance to petitioner of two final notices of intent to levy. One notice dealt with petitioner's 1989, 1990, and 1991 tax years, and the other notice dealt with petitioner's 1994 tax year. In both instances, petitioner responded timely with a Request for a Collection Due Process Hearing. A hearing was held with petitioner by telephone with respect to both requests. Thereafter, respondent issued separate notices of determination advising petitioner that respondent would proceed with collection. This petition for review followed. The Federal income taxes and penalties at issue are based on two notices of deficiency issued to petitioner and his spouse, Joyce E. Beery, as follows:2 Year Deficiency Sec. 6662(a) Penalty 1989 $28,242 $5,648 1990 24,401 4,880 1991 4,624 -- 1994 21,592 4,318 2 The collection activity was instituted only against petitioner and not his spouse. One notice of deficiency was for the years 1989, 1990, and 1991, and the other notice of deficiency was for the years 1992, 1993, and 1994. The collection activity at issue is not directed to petitioner's 1992 and 1993 tax liabilities. The record is unclear as to the amount owing for the 1989, 1990, and 1991 tax years; however, for the year 1994, the final notice of intent to levy to petitioner stated a total of taxes, penalties, and interest of $34,447.88.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011