- 6 - 6212 and 6213, since I have not been able to locate them. Without your furnishing me with these documents and information, I will be unable to “ascertain” * * * whether the individual who sent me the Deficiency Notice was authorized to do so, and whether I am le- gally required to take any notice of it. * * * [Reproduced literally.] On January 8, 2001, respondent assessed petitioner’s tax, as well as any penalties and interest as provided by law, for each of his taxable years 1997 and 1998. (We shall refer to those assessed amounts, as well as interest as provided by law accrued after January 8, 2001, as petitioner’s unpaid liabilities for 1997 and 1998.) On January 8, 2001, respondent issued to petitioner a notice of balance due with respect to petitioner’s unpaid liabilities for 1997 and 1998. On August 14, 2001, respondent issued to petitioner a final notice of intent to levy and notice of your right to a hearing (notice of intent to levy) with respect to his taxable years 1997 and 1998. On or about September 10, 2001, in response to the notice of intent to levy, petitioner filed Form 12153, Request for a Collection Due Process Hearing (Form 12153), and requested a hearing with respondent’s Appeals Office (Appeals Office). Petitioner attached a document to his Form 12153. That document stated in pertinent part: I am requesting a “Due Process Hearing” as out- lined in From 12153. I am “challenging the appropri-Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011