- 3 - Respondent assessed petitioner’s tax liabilities for 1992 and 1993 on November 26 and October 1, 2001, respectively; the assessments amounted to $15,779 for 1992 and $6,092 for 1993. On April 15, 2002, respondent sent petitioner Notices of Intent to Levy for 1992 and 1993. On May 30, 2002, petitioner sent respondent Form 12153, Request for a Collection Due Process Hearing, in which he contested the collection proceedings with respect to the years at issue and requested a section 6330 hearing (hearing). In his statement of reasons for disputing respondent’s actions, petitioner asserted that his liabilities were discharged in the bankruptcy proceedings, and that “[t]he Service has for over 2 years constructive notice of my situation.” On November 12, 2002, respondent held a telephonic hearing with petitioner. On January 17, 2003, respondent sent petitioner a Notice of Determination, stating there was no record that petitioner’s liabilities were discharged in bankruptcy and indicating respondent’s intent to proceed with the levy with respect to the years at issue.5 Petitioner filed his amended petition contesting the Notice of Determination with this Court on February 26, 2003. In the 5 The Notice of Determination stated, in the section captioned “Issues Raised by the Taxpayer” that “[y]ou contend that the liabilities at issue were discharged in bankruptcy, but there is no record of that.”Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011