- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011