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On January 4, 2000, respondent issued a notice of deficiency
to petitioner with respect to 1997. In that notice, respondent
(relying on the information used in preparing the 1997 substitute
return3) determined that petitioner was liable for an income tax
deficiency of $8,644, a delinquency addition to tax under section
6651(a)(1) of $2,161, and an estimated tax addition to tax under
section 6654 of $462.44.
Petitioner received the notice of deficiency; he did not
contest respondent’s determinations by filing a petition in this
Court. On May 8, 2000, respondent assessed the determined
deficiency, the estimated tax addition, the late filing addition,
and statutory interest.
Petitioner failed to pay the assessed liabilities for 1997;
consequently, on November 13, 2000, the IRS filed a notice of
Federal tax lien.
On November 10, 2000, the IRS sent petitioner a notice
entitled “Notice of Federal Tax Lien Filing and Your Right to a
Hearing Under I.R.C. 6320” (the notice of Federal tax lien
filing) with respect to petitioner’s outstanding tax liability
for 1997. On November 22, 2000, petitioner submitted to the IRS
a Form 12153, Request for a Collection Due Process Hearing, dated
November 21, 2000, and an attachment thereto. In the attachment,
3Petitioner was allowed estimated expenses of $33,298 on the
basis of the profit ratio shown on petitioner’s 1996 return.
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