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FINDINGS OF FACT
Some of the facts have been stipulated. We incorporate the
stipulated facts and accompanying exhibits into our findings by
this reference. Petitioner resided in Milwaukee, Wisconsin, at
the time of filing the petition.
Although petitioner filed his Federal income tax returns for
1997, 1998, and 1999,2 petitioner failed to pay the amounts of
tax shown as due for each year. Petitioner did not receive a
notice of deficiency. On October 4, 1999, November 27, 2000, and
December 11, 2000, respondent assessed the unpaid income tax
shown on petitioner’s returns as well as additions to tax and
interest against petitioner and sent to petitioner notices of
balance due for 1997, 1998, and 1999, respectively.
Subsequently, from October 25, 1999, through April 16, 2001,
respondent sent to petitioner additional notices of balance due
and notices of intent to levy. Petitioner failed to make
payments on the outstanding liabilities.
On August 11, 2001, respondent mailed to petitioner a Final
Notice - Notice of Intent to Levy and Notice of Your Right to a
Hearing covering the taxable years 1997, 1998, and 1999. On
August 20, 2001, petitioner timely submitted Form 12153, Request
for a Collection Due Process Hearing, requesting a hearing under
section 6330 (the hearing). During a telephone call on January
2Petitioner filed as “single” for all 3 years.
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