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initiated a proceeding, Parikh v. Commissioner, docket No. 13843-
91, which this Court dismissed for lack of jurisdiction.
On April 14, 1993, petitioner filed his 1992 return but did
not pay the self-assessed $1,429 tax due. On May 24, 1993,
respondent assessed this deficiency.
On November 30, 2001, respondent sent petitioner a Final
Notice – Notice of Intent to Levy and Notice of Your Right to a
Hearing, relating to 1988 and 1992. Petitioner, on December 27,
2001, sent respondent Form 12153, Request for a Collection Due
Process Hearing, relating to those years.
On May 15, 2002, the Appeals officer sent petitioner a
letter proposing a section 63301 hearing (hearing) on July 9,
2002. On May 29, 2002, the Appeals officer held a telephone
hearing with petitioner, but petitioner insisted on keeping the
July 9, 2002, scheduled hearing. During the May 29, 2002,
hearing, the Appeals officer discussed with petitioner the notice
relating to 1988 and petitioner’s self-assessed return relating
to 1992.
On August 6, 2002, respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) under Section 6320
and/or 6330 relating to 1988 and 1992. In response, on September
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
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Last modified: May 25, 2011