- 3 - 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.” On April 22, 2002, petitioner and his representative attended a hearing before Appeals Officer Serena Wong. At the hearing, petitioner contended that respondent had not assessed the income tax liabilities. On October 11, 2002, the Appeals Office sent to petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination). In the notice of determination, the Appeals Office determined that petitioner’s income tax liabilities were timely assessed, and the assessments were “properly based on established law, policy and procedure.” On October 30, 2002, petitioner’s petition contesting respondent’s determination was filed in this Court. In the petition, petitioner alleged that “the Internal Revenue Service abused its discretion in making the findings and conclusions it did and abused its discretion in rejecting petitioner’s offer in compromise.” We held a trial in this case on October 22, 2003, at which petitioner testified. On September 20, 2004, we filed our Memorandum Opinion in Kun I in which we rejected petitioner’s contention that the income tax liabilities had not been timelyPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011