- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
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