Luis A. Cortes - Page 5




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          income of $0 and total tax of $0.                                           
               On a date not disclosed by the record, but before respondent           
          issued a notice of determination concerning collection action(s)            
          under section 6320 and/or 6330 (notice of determination), the               
          Appeals officer provided petitioner with a certified transcript             
          of his account with respect to each of his taxable years 1995 and           
          1999.                                                                       
               On July 11, 2001, the Appeals Office issued to petitioner a            
          notice of determination with respect to petitioner’s unpaid                 
          liability for each of his taxable years 1995 and 1999.  An                  
          attachment to the notice of determination stated in pertinent               
          part:                                                                       
               Verification of Legal and Procedural Requirements                      
               The Secretary has provided sufficient verification that                
               the requirements of any applicable law or administra-                  
               tive procedure have been met.  Certified transcripts                   
               were requested and reviewed and copies provided to you.                
               Notice and demand was issued by regular mail for the                   
               above years to your last known address, as required                    
               under IRC 6303.  The Final Notice of Intent to Levy                    
               (Letter 1058) was sent by certified mail dated August                  
               31, 2000.  You responded timely with a request for a                   
               Collection Due Process Hearing.                                        
               This Appeals Officer has had no prior involvement with                 
               respect to these liabilities.                                          
               Issues Raised by the Taxpayer                                          
               The case file shows you were audited for 1995, issued a                
               statutory notice for 1995 and choose [sic] not to file                 
               a petition for 1995 contesting the tax liability.  In                  
               addition the case file shows you filed a 1040 for 1999.                
               At the hearing held on May 8, 2000 [sic] you provided                  





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