- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011