- 3 -
September 9, 2002, respondent issued to petitioner a notice of
balance due for the taxable year 1995.
On January 21, 2003, respondent mailed to petitioner a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing
requesting that petitioner pay his outstanding tax liability for
1995. On February 12, 2003, petitioner submitted to respondent a
Request for Collection Due Process Hearing challenging the
validity of the assessment for 1995. Specifically, petitioner
argued that respondent failed to provide petitioner with either a
record of the assessment or a notice of the assessment.
On July 22, 2003, the parties met for the purpose of
conducting an administrative hearing regarding respondent’s
proposed levy. However, the hearing was terminated when the
Appeals officer informed petitioner that he would not be
permitted to make an audio recording of the hearing.
On July 31, 2003, respondent mailed to petitioner a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330. In the notice, respondent determined that it
was appropriate to proceed with the proposed levy because: (1)
Petitioner had previously challenged respondent’s notice of
deficiency for 1995 in the Tax Court, and, therefore, he was
barred from challenging his underlying tax liability pursuant to
section 6330(c)(2)(B); (2) petitioner failed to file Federal
income tax returns from 1995 to 2002, and, therefore, he was not
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011