David M. Priestly, Jr. - Page 6

                                        - 6 -                                         
          prompted to explain his or her disagreement with respondent’s               
          proposed collection activity, petitioner wrote:                             
               I do not owe the amount shown.  I do have receipts to                  
               substantiate my deductions.  They are with the IRS                     
               downtown Los Angeles branch.  I need time to retrieve                  
               them.  Ms. Snoody [sic] (rev agt) is aware of this.                    
               * * * I did not have the opportunity to dispute tax.                   
               In response to petitioner’s request for a hearing, in a                
          letter dated April 15, 1999, addressed to petitioner at the                 
          Diamond Bar address, an Appeals officer, who was unaware that               
          petitioner was incarcerated at the time, scheduled a hearing for            
          May 20, 1999.  Petitioner apparently contacted the Appeals                  
          officer by telephone and requested that the hearing be                      
          rescheduled for another date.  Petitioner did not notify the                
          Appeals officer that he was incarcerated; the Appeals officer was           
          aware that petitioner had been convicted of criminal tax offenses           
          but believed that petitioner’s incarceration had been deferred              
          pending appeal of his criminal conviction.  The hearing was                 
          rescheduled for June 17, 1999.  Petitioner failed to attend the             
          June hearing because he was incarcerated.                                   
               In a Notice of Determination Concerning Collection Action(s)           
          Under Section 6320 and/or 6330, dated July 6, 1999, addressed to            
          petitioner at the Diamond Bar address, respondent determined to             
          proceed with the proposed collection activity because:  (1) “All            

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011