Edward P. Heaphy - Page 3

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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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