- 4 - dismissal order was not appealed and became final on September 25, 2000. On November 20, 2000, respondent assessed income tax of $56,771 and interest of $456,023.09 and sent petitioner a notice of balance due.7 On November 29, 2001, respondent issued a Final Notice--Notice of Intent to Levy and Notice of Your Right to a Hearing. On December 14, 2001, petitioner timely submitted Form 12153, Request for a Collection Due Process Hearing, requesting a hearing under section 6330 (the hearing). On July 10, 2002, petitioner’s counsel attended the hearing conducted by Appeals Officer Joann Mares. At the hearing, petitioner’s counsel argued that the statutory limitations period for assessment (the limitations period) had expired before respondent assessed petitioner’s 1980 income tax liability. Petitioner’s counsel raised no other issues at the hearing. With respect to alternative collection methods, petitioner’s counsel expressed interest in discussing an installment agreement at a later date if Appeals Officer Mares determined that the limitations period had not expired before respondent’s assessment. Petitioner’s counsel did not provide any financial information at the hearing or propose an actual installment agreement to Appeals Officer Mares. 7The amount of the assessment was reduced by payments and credits totaling $140,944.67 to arrive at the balance due.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011