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June 10, 1996, petitioner filed a demand for abatement and claim
for a refund of his 1992 taxes. No abatement or refund was made.
On April 15, 1998, petitioner filed a 1997 income tax return
on which he reflected $30,000 of income, but no taxable income,
and he sought a refund of $948.24 in withheld tax. Attached to
the 1997 return was a Form W-2, Wage and Tax Statement,
reflecting the payment of $30,012.65 of wage income to
petitioner. On December 22, 1998, respondent mailed a notice of
deficiency to petitioner determining a $3,514 income tax
deficiency and a $76.97 addition to tax under section 6651(a).
With respect to that notice, petitioner filed what was deemed an
imperfect petition, and this Court, on March 18, 1999, ordered
him to file a proper petition. Petitioner failed to do so, and
on August 18, 1999, his case concerning the 1997 tax year was
dismissed for lack of jurisdiction.
Petitioner requested a precollection hearing in response to
the notice of intent to collect, and the Appeals officer set a
hearing date. Petitioner failed to attend the scheduled
conference and, instead, asked for and was granted a rescheduled
date for the hearing. The hearing was held on March 21, 2001,
and it was tape recorded. At the hearing, the Appeals officer
provided petitioner with Forms 4340, Certificates of Assessments,
Payments, and Other Specified Matters.
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