- 9 -
in Letter 1058, dated 08/27/2001, which was mailed
certified to the taxpayer’s last known address. The
taxpayer responded with Form 12153, Request for a
Collection Due Process Hearing, which was received and
date stamped 09/28/2001.
The taxpayer appeared in person for his Collection Due
Process hearing, his spouse chose not to come to the
hearing. Settlement Officer Mike Freitag conducted the
hearing. Settlement Officer Donna Fisher was also in
attendance.
At the hearing the taxpayer was asked if he had any
recording devices. He said he did not have one. He
was again reminded that no recording of Appeals’ hear-
ings is allowed.
* * * * * * *
Issues Raised by the Taxpayer
* * * * * * *
The IRS * * * sent statutory notices of deficiency
dated May 21, 1999 to the taxpayers at their last known
address asserting a deficiency for the taxable years
1995, 1996, and 1997. The taxpayers received the
notices of deficiency in time to petition the Tax Court
for a redetermination of the deficiencies. They did
not file a timely petition to Tax Court, but responded
to the notices with a letter dated 08/18/1999 with
their same non-filer arguments. The tax was properly
assessed.
The IRS * * * sent statutory notices of deficiency
dated 04/07/2000 to the taxpayers at their last known
address asserting a deficiency for the taxable year
1998. The taxpayers received the notices of deficiency
in time to petition the Tax Court for a redetermination
of the deficiencies. They did not file a timely peti-
tion to Tax Court * * *
After being shown one of the notices of deficiencies,
he stated he did receive them. Appeals then stated
that as he received those notices and failed to peti-
tion the tax court, he could not argue the liability at
the hearing.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011