Yakuba G. Brown - Page 4

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          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 dispute                

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