George G. Green - Page 3

                                        - 3 -                                         
                           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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