Benedict John Casey - Page 4

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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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