- 4 -
Daniel L. Shirah (Mr. Shirah) thereafter sent petitioner a letter
dated October 3, 2001, scheduling the requested conference.
A telephone conference between petitioner and Mr. Shirah was
conducted on October 19, 2001. During the conference there
ensued some discussion of collection alternatives, among other
things, and after the conference Mr. Shirah sent to petitioner
for his completion Form 656, Offer in Compromise, and Form 433-A,
Collection Information Statement for Wage Earners and Self-
Employed Individuals. Petitioner began filling out the documents
but never submitted completed forms to respondent.
On January 10, 2002, respondent issued to petitioner the
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 sustaining proposed collection action.3
Petitioner on February 5, 2002, filed with the Tax Court an
imperfect petition challenging the notice. The petition
reflected that petitioner wished to have his case heard for two
reasons; i.e., he was experiencing hardship due to the disability
of end stage renal disease, and he had now found proof that his
liability was too great.
Petitioner then filed an amended petition on March 6, 2002,
consisting of 11 handwritten pages explaining his circumstances.
He indicated therein that the tax years involved were 1995
3 We note that the notice of determination refers in
apparent error to “levy”, rather than “lien”, action.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011