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by levy Federal income taxes owing by petitioner for the years
1992 and 1994 should proceed. That determination was preceded by
respondent's issuance to petitioner of a notice of intent to levy
and of petitioner's right to a hearing in connection with an
assessed balance of income taxes and statutory additions totaling
$8,349.62, $4,717.20, and $2,881.40, respectively, for 1992,
1994, and 1998. In his petition for review, petitioner did not
challenge respondent's determination to proceed with collection
for the year 1998.
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and are made part hereof.
At the time the petition for review was filed, petitioner was a
legal resident of Houston, Texas.
An attachment to the notice of determination prepared by
respondent's Appeals officer states that, at the hearing,
petitioner "only argues that he did not owe the proposed taxes"
and that, under section 6330(c)(2)(B), "none of the three
disputed liabilities are appropriate for consideration as a part
of the Request for Collection Due Process Hearing". The
statement also states that "joint liability" was not at issue,
that collection alternatives were not offered, and concludes that
collection activity could proceed.
As noted earlier, petitioner did not challenge the
determination for the 1998 tax year in his petition to this
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