- 2 -
proceed with collection of tax liabilities for the years 1995 and
1996.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Wenham, Massachusetts, on the date the petition was filed in this
case.
Petitioner did not file Federal income tax returns for the
years 1995 and 1996. On March 31, 1999, respondent sent to
petitioner, via certified mail, two notices of deficiency. The
notices determined deficiencies and additions to tax totaling
$21,364.19 for 1995 and $34,649.48 for 1996. Respondent provided
the Court with a copy of the certified mailing list, stamped
March 31, 1999, showing that respondent mailed the notices to
petitioner at his residential address. Petitioner did not
petition this Court with respect to either of the notices of
deficiency. On August 30, 1999, respondent assessed the 1995 and
1996 tax liabilities as determined in the notices of deficiency.
On June 11, 2001, respondent mailed to petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 for the years 1995 and 1996. The notice reflected unpaid
tax liabilities for 1995 and 1996 in the amounts of $1,506.92 and
$39,576.66, respectively. In response to this notice, petitioner
filed a Request for a Collection Due Process Hearing. The only
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011