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On February 18, 1997, respondent sent petitioner a notice of
deficiency determining an income tax deficiency plus additions to
tax under sections 6651 and 6654 for 1994 and 1995. Petitioner
returned the notice to respondent with the words “Acceptance
Refused For Cause Without Dishonor” handwritten thereon and did
not petition this Court with respect to the notice. Respondent
assessed the unpaid tax, additions to tax, and interest for 1995
on July 14, 1997, and sent petitioner a Statutory Notice of
Balance Due on the same date.
On August 27, 1999, respondent sent petitioner a notice of
deficiency, determining income tax deficiencies and additions to
tax under sections 6651(a)(1) and (2), and 6654 for 1996 and
1997. Petitioner returned the notice to respondent with the
words “Acceptance Refused for Cause Without Dishonor” handwritten
thereon and did not petition this Court with respect to the
notice. Respondent assessed the unpaid tax, additions to tax,
and interest for 1996 and 1997 on February 7, 2000, and sent
petitioner a Statutory Notice of Balance Due on the same date.
On November 20, 2000, respondent sent petitioner a Letter
1058, Final Notice - Notice of Intent to Levy and Notice of Your
Right to a Hearing, with respect to petitioner’s tax liabilities
for 1995, 1996, and 1997. On December 18, 2000, petitioner
submitted to respondent a Form 12153, Request for a Collection
Due Process Hearing, covering the years in the Letter 1058. On
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