- 3 - further advised that there was no right to dispute a decision by the Appeals Office. In July and August 2003, there were communications between petitioner and the IRS. On August 4, 2003, the IRS representative received by fax from petitioner a Form 433-A, Collection Information Statement for Wage Earners and Self-Employed Individuals, containing financial information provided by petitioner. The IRS representative concluded that the information included in the statement was incomplete and inaccurate. Petitioner was advised of the above in a telephone conference. On August 15, 2003, respondent issued a Notice of Determination Concerning Collection Actions(s) with respect to the taxable year 2000, informing petitioner of the opportunity to file a petition with this Court, and that the IRS would proceed with collection action if no petition was filed. Also, on August 15, 2003, respondent issued petitioner a Decision Letter with respect to the taxable years 1997, 1998, and 1999. The letter advised petitioner of the IRS’s intent to proceed with collection action and further that petitioner would not have an additional opportunity to dispute the decision, since a request for hearing was not filed within the time provided under section 6330. A petition was filed with the Court on September 22, 2003. At the time the petition was filed, petitioner resided in Moreno Valley, California. The petition indicates that the disputePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011