- 4 - Form 1099-R. Respondent’s notice of deficiency was mailed only to, and received only by, petitioner. Petitioner did not file a petition in this Court with regard to the above notice of deficiency. On February 24, 1997, respondent assessed the $9,285 income tax deficiency set forth in the notice of deficiency against both petitioners. On June 16, 2000, respondent mailed to both petitioners a notice of intent to levy relating to the above 1993 tax assessment. On July 14, 2000, petitioner submitted to respondent a request for a section 6330 hearing. On January 24, 2002, respondent’s Appeals officer mailed to petitioners a letter notifying petitioners that respondent had received petitioners’ request for a hearing. On January 29, 2002, petitioner contacted the Appeals officer and scheduled a hearing. On February 5, 2002, petitioner and the Appeals officer discussed the notice of intent to levy over the telephone (telephone conference).3 During the telephone conference, petitioner attempted to challenge the underlying tax liability by claiming that the total $109,737 annuity distribution had been included on his deceased 3 Originally, the Appeals Office hearing was scheduled to be held in respondent’s office on Feb. 5, 2002, but, on the morning of Feb. 5, petitioner called the Appeals officer and stated that he could not attend the hearing at respondent’s office. The Appeals officer suggested that they could discuss the notice of intent to levy over the telephone, to which petitioner agreed and which they proceeded to do.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011