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At the hearing, Mr. Wergin offered petitioner the
opportunity to enter into an installment agreement. Petitioner
declined the offer. Mr. Wergin gave petitioner a Form 433-A,
Collection Information Statement for Wage Earners and Self-
Employed Individuals, so he could consider whether petitioner
should be placed in currently not collectible status. Mr. Wergin
asked petitioner to return the Form 433-A by May 27, 2003.
On May 27, 2003, petitioner faxed Mr. Wergin a letter
discussing three $500 checks petitioner claimed to have mailed to
the IRS between January 1995 and sometime in 1996 and a
handwritten ledger with amounts petitioner claimed were taxes due
and tax paid for 1993 through 2000. Petitioner had already
provided the ledger to Mr. Wergin at the hearing.
That same day, Mr. Wergin called petitioner to advise him
that he was closing his case, but petitioner could still submit
proof of missing payments for 1996 and 1998 to IRS Compliance.
Petitioner stated that he identified all of his payments in the
transcripts for 1994 through 2001 that Mr. Wergin provided to
him.
On July 7, 2003, respondent issued a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330 to
petitioner regarding his 1996 and 1998 tax years (notice of
determination). As of the date of the notice of determination,
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