Albert M. Kun - Page 3

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          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 timely              






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