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2, 2000, the Court of Appeals stayed issuance of the mandate
pending petitioner’s petition for writ of certiorari to the U.S.
Supreme Court. On August 8, 2000, petitioner timely requested a
hearing for his 1994 tax year by submitting Form 12153, Request
for a Collection Due Process Hearing. During subsequent
conversations with respondent, petitioner consented to the
inclusion of his 1993 tax year, in addition to his 1994 tax year,
for purposes of the section 6330 hearing.
On October 6, 2000, petitioner filed a petition for writ of
certiorari with the Supreme Court. Respondent had the option to
file a response to the petition, but declined to do so.
Therefore, in accordance with Supreme Court rules, the Solicitor
General timely filed a waiver of the right to respond on behalf
of respondent. Approximately 3 weeks later, on November 6, 2000,
the Supreme Court denied petitioner’s petition for writ of
certiorari. Karara v. Commissioner, 531 U.S. 980 (2000).
On September 24, 2001, respondent applied an overpayment of
tax by petitioner in the amount of $300 toward his 1993 tax
liability.
Petitioner and the Appeals officer engaged in telephone
conferences on September 5 and October 4 and 5, 2001. During
these conferences, respondent notified petitioner that the
assessments were valid and subject to collection because of
petitioner’s failure to post a bond while his appeals were in
progress. See sec. 7485. In response, petitioner raised the
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