Jason R. Henderson - Page 2

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          petitioner has not raised any relevant issues relating to the               
          unpaid tax or the proposed levy, we hold that it was not an abuse           
          of discretion for respondent to determine to proceed with                   
          collection.                                                                 
                                  FINDINGS OF FACT                                    
               On April 15, 1999, petitioner and his wife filed a joint               
          Federal income tax return for 1998.1  On the 1998 return,                   
          petitioner reported his total income as zero and his total tax as           
          zero.  On February 22, 2000, respondent issued petitioner a                 
          notice of deficiency for 1998, determining a deficiency of                  
          $4,331.  Petitioner did not petition this Court with respect to             
          the notice of deficiency.  On July 9, 2001, respondent assessed             
          the deficiency, along with additions to tax and interest.  On               
          January 18, 2002, respondent sent petitioner a Final Notice--               
          Notice of Intent to Levy and Notice of Your Right to a Hearing              
          Under Section 6330 with respect to petitioner’s income tax                  
          liability for 1998.  On February 4, 2002, petitioner submitted a            
          Form 12153, Request for a Collection Due Process Hearing, to the            
          Internal Revenue Service Office of Appeals requesting a hearing             
          under section 63302 (hearing).                                              




               1 Although petitioner and his wife filed a joint tax return            
          for 1998, her liability is not at issue in this proceeding.                 
               2 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code as amended.                                       




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