- 2 -
FINDINGS OF FACT
Some of the facts have been stipulated. We incorporate the
stipulated facts and the accompanying exhibits into our findings
by this reference. Petitioner resided in San Francisco,
California, when he filed the petition.
Petitioner timely filed tax returns for 1995 through 1999
but failed to pay the amounts shown as due on the returns. On
May 3, 2001, respondent sent to petitioner a Notice of Federal
Tax Lien Filing and Your Right to a Hearing Under IRC 6320 for
1995 through 1999. On June 4, 2001, petitioner mailed to
respondent Form 12153, Request for a Collection Due Process
Hearing, requesting a hearing with respect to all 5 taxable
years. Petitioner’s Form 12153 stated: “I believe this bill is
incorrect. These taxes were never assessed. I am requesting a
minimum of 60 days extension.”
On April 22, 2002, petitioner and petitioner’s
representative, Hector Vasquez, attended a hearing with Appeals
Officer Serena Wong. At the hearing, petitioner contended that
respondent had not assessed the income tax liabilities.
Petitioner also submitted an offer-in-compromise of $1,000 on the
basis of doubt as to collectibility. Petitioner’s offer-in-
compromise covered his income tax liabilities for 1985 through
2001, which then exceeded $180,000.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011