- 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 dispute
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011