Alfred J. Martin - Page 4

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          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.                  





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