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statement so that an offer in compromise might be considered and
told petitioner to select, prior to January 2, 2001, one of the
collection alternatives discussed during the hearing. Petitioner
did not select a collection alternative or submit any additional
evidence relating to his tax liability. On January 22, 2001,
respondent issued a Notice of Determination Concerning Collection
Action(s) Under Sections 6320 and 6330 (the determination)
denying petitioner’s appeal.
On February 21, 2001, petitioner, while residing in
Silverdale, Washington, filed his petition for review of the
determination. On October 9, 2001, respondent served upon
petitioner Forms 4340, Certificates of Assessments, Payments, and
Other Specified Matters (Forms 4340) for all years in issue and a
request for admissions. Petitioner did not respond to the
request for admissions.
On January 28, 2002, respondent filed with the Court a trial
memorandum. In the trial memorandum, respondent stated: (1)
Petitioner did not file tax returns relating to 19781 through
1984 but did file returns relating to 1985 through 1992, 1994,
and 1997; (2) “quick assessments” made on October 2, 1995,
relating to 1978 through 1984 indicated that petitioner was the
subject of a jeopardy assessment; (3) notices of deficiency dated
1 Respondent did not include 1977, one of the tax years at
issue.
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