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petitioner’s 1998 tax of $7,754 and an accuracy-related penalty
under section 6662 of $963.80. The notice of deficiency was
returned to respondent marked “not deliverable as addressed,
unable to forward”. Petitioner had moved and left no forwarding
address, and so he did not receive the notice of deficiency.
Petitioner did not file a petition for redetermination of the
deficiency for 1998.
Petitioner filed a petition in the U.S. Bankruptcy Court for
the Southern District of Texas on April 6, 2000. The bankruptcy
court discharged petitioner’s debts on July 24, 2000.
C. Notice of Federal Tax Lien and Notice of Intent To Levy
On December 17, 2001, respondent issued to petitioner a
Notice of Intent to Levy and Notice of Your Right to a Hearing
relating to his 1998 tax liability. The notice was returned to
respondent marked “unclaimed”. Petitioner did not request a
hearing under section 6330(b) in response to respondent’s notice
of proposed levy. On February 1, 2002, respondent issued to
petitioner a Notice of Federal Tax Lien Filing and Your Right to
a Hearing Under IRC 6320 relating to petitioner’s unpaid taxes
for 1998.2
2 The notice of Federal tax lien also relates to a sec.
6702 frivolous return penalty assessed for 1999.
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Last modified: May 25, 2011