- 3 - On May 24, 1999, respondent assessed the tax that petitioner reported in his 1998 return.2 On September 17, 2001, respondent assessed an addition under section 6651(a)(2) to the unpaid portion of such tax and interest as provided by law. (We shall refer to any such unpaid assessed amounts, as well as interest as provided by law accrued after September 17, 2001, as petitioner’s unpaid liability for 1998.) On September 17, 2001, respondent issued to petitioner a notice of balance due with respect to petitioner’s unpaid liabil- ity for his taxable year 1998. On April 8, 2002, respondent issued to petitioner a final notice of intent to levy and notice of your right to a hearing (notice of intent to levy) with respect to his taxable year 1998. On or about April 28, 2002, in response to the notice of intent to levy, petitioner filed Form 12153, Request for a Collection Due Process Hearing (Form 12153), and requested a hearing with 2On Oct. 19, 2001, respondent issued to petitioner a notice of deficiency (notice) with respect to his taxable year 1998. In that notice, respondent determined a deficiency of $815 in petitioner’s tax for that year. Petitioner did not file a petition with the Court with respect to that notice. On Apr. 29, 2002, respondent assessed the deficiency of $815 that respondent determined in the notice relating to petitioner’s taxable year 1998. That deficiency is not part of the collection action as determined in the notice of determination concerning the collec- tion action for petitioner’s taxable year 1998 upon which this case is based. Respondent indicates in respondent’s motion that if respondent proposes to collect the deficiency of $815 that respondent determined in the notice relating to petitioner’s taxable year 1998, “Petitioner will be entitled to a separate CDP hearing” with respect to any such proposed collection action.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011