Tim W. Holliday - Page 3

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               Petitioner did not timely file a Federal income tax return             
          for 1996.  On September 14, 1998, respondent prepared a                     
          substitute for return, and 3 days later petitioner submitted a              
          return that was filed as an amended return.  The return                     
          petitioner submitted reported $5,805 of tax due, which respondent           
          assessed.                                                                   
               Petitioner timely filed 1997 and 1998 individual Federal               
          income tax returns, reporting tax due of $7,037 and $7,842,                 
          respectively, which respondent assessed.                                    
               On September 21, 2000, petitioner filed amended returns for            
          1993, 1994, 1995, 1996, and 1997 reporting the tax due on each              
          amended return as zero.  Respondent treated these amended returns           
          as claims for refund and denied them.                                       
               On April 9, 2001, respondent issued a Letter 1058, Final               
          Notice, Notice of Intent to Levy and Notice of Your Right to a              
          Hearing, to petitioner for the unpaid balances of the                       
          aforementioned assessments for the tax years 1992, 1993, 1994,              
          1995, 1996, 1997, and 1998.  On May 1, 2001, petitioner submitted           
          to respondent a Form 12153, Request for a Collection Due Process            
          Hearing.  In his request, petitioner advised that he would have a           
          stenographer present at the hearing.                                        
               By letter dated May 3, 2002, the Appeals officer advised               
          petitioner that neither stenographic nor audio recording of the             
          hearing would be permitted.  A hearing was held on May 22, 2002,            






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