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Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Chesapeake, Virginia, at the time he
filed the petition in this case.
On June 18, 2000, petitioner filed a Federal income tax
(tax) return for his taxable year 1997 (return). In that return,
petitioner showed total income of $41,914 consisting of Schedule
C net profit, total tax of $11,727, tax due of $8,487, and an
estimated tax penalty of $413. When petitioner filed his return,
he did not pay the tax due shown in his 1997 return.
On July 17, 2000, respondent assessed petitioner’s tax, as
well as additions to tax and interest provided by law, for his
taxable year 1997.2 (We shall refer to those assessed amounts,
as well as interest as provided by law accrued after July 17,
2000, as petitioner’s unpaid liability for 1997.)
Respondent issued to petitioner the notice and demand for
payment required by section 6303(a) with respect to petitioner’s
unpaid liability for 1997.
On June 28, 2001, respondent issued to petitioner a final
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to petitioner’s unpaid
2Respondent assessed petitioner’s tax after correcting the
total tax shown in petitioner’s return for mathematical or
computational errors.
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Last modified: May 25, 2011