George R. and Karen S. Kemper - Page 9

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               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.                                                           






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