- 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