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Penalties and Unpaid Balance
Year Tax Additions to tax Interest of Assessment
1995 $2,636,238 $2,089,273 $3,498,807 $8,233,318
1996 128,792 101,860 136,760 367,412
1997 79,135 62,790 64,750 206,705
1998 52,583 41,282 32,646 126,511
1999 1,868,443 813,440 652,979 3,334,862
On May 2, 2003, respondent issued to petitioner a Notice of
Jeopardy Levy and Right of Appeal determining that collection of
petitioner's Federal income taxes for taxable years 1995, 1996,
1997, 1998, and 1999 was in jeopardy and that issuance of a levy
to collect those taxes was appropriate.3
On May 20, 2003, petitioner requested relief from the
jeopardy assessment and jeopardy levy. On July 16, 2003, the
Internal Revenue Service Office of Appeals held an administrative
hearing under section 7429. On July 17, 2003, the Appeals
officer handling petitioner's case faxed a letter to petitioner's
attorney advising him that petitioner's "case will close out on
July 21, sustaining the jeopardy assessment and advising * * *
[petitioner's attorney] that he [petitioner] has judicial review
rights that should be exercised BEFORE Sept. 4, 2003."
3 Although respondent issued to petitioner what purports to
be a notice of jeopardy levy, it does not appear that respondent
has levied on petitioner's property inasmuch as that property is
currently tied up in court proceedings in Canada. On May 2,
2003, respondent did, however, issue a Form 668(Y), Notice of
Federal Tax Lien, for the unpaid balances of assessment for 1995
through 1999, totaling $12,268,808, that reflects the filing of a
tax lien with the Clerk of Superior Court, Floyd County, Rome,
Georgia.
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Last modified: May 25, 2011