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Background
The record establishes and/or the parties do not dispute the
following:
At the time petitioner timely filed the petition in this
case, he resided in Powhatan, Virginia.
On February 5, 2002, respondent’s Appeals Office (Appeals
Office) mailed to petitioner a notice of determination concerning
collection actions(s) under section 6320 and/or 63302 (notice of
determination). That notice, which pertained to petitioner’s
taxable years 1990, 1991, 1992, 1993, and 1996, stated in perti-
nent part:
Summary of Determination
The Internal Revenue Service mailed a Letter 1058,
Final Notice - Notice Of Intent To Levy And Notice Of
Your Right To A Hearing, on March 7, 2001 concerning
the unpaid Federal income tax (Form 1040) for the
periods ending noted above [taxable years 1990, 1991,
1992, 1993, and 1996]. In response to the letter you
submitted Form 12153, received April 2, 2001, request-
ing a Collection Due Process Hearing. Your request was
forwarded to this Appeals Office.
Since you did not respond to the Appeals Officer’s
request for information nor attend the scheduled con-
ference on October 9, 2001, we will return you [sic]
case to the Collection function for collection appro-
priate action.
An attachment to the notice of determination stated in pertinent
part:
2All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011