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photocopied invoices, was the first page of the aforementioned
notice of deficiency.
In a letter to petitioner dated August 1, 1995, and mailed
to the Madeira Drive address, the chief of respondent’s
examination division indicated that the information petitioner
had submitted on June 15, 1995, had been considered but did not
support a change to the adjustments previously proposed. The
letter noted that if petitioner disagreed with these findings, he
could petition the Tax Court, pursuant to the instructions
contained in the notice of deficiency.3
Petitioner did not petition the Tax Court to challenge the
determinations in the notice of deficiency.
Collection Activity
Respondent sent petitioner a Final Notice--Notice of Intent
to Levy and Notice of Your Right to a Hearing, dated November 30,
2000. On Form 12153, Request for a Collection Due Process
Hearing, dated December 20, 2000, and showing an address of 2314
Parker Lane #11, Austin, Texas (the Parker Lane #11 address),
petitioner requested an Appeals Office hearing.4 On the Form
12153, the only issue that petitioner raised with respect to the
3 As previously noted, the notice of deficiency indicated an
Aug. 15, 1995, deadline for petitioner to petition the Tax Court.
4 The address listed on the Form 12153 is simply “2314
Parker Ln. # 11”, without a city or State designation. On cross
examination, petitioner acknowledged that the address listed on
the Form 12153 is in Austin, Texas.
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