- 3 - representing limited partners in tax shelter litigation, filed a petition with this Court on behalf of petitioner and Amilu seeking a redetermination of their 1980 deficiency.2 Mr. Berg attached to the petition a copy of Amilu’s notice. In Martin I, we granted petitioner’s request to dismiss him from the 1980 deficiency case for lack of jurisdiction, concluding that petitioner did not file, authorize the filing of, or ratify the filing of the petition Mr. Berg signed and submitted. On November 20, 2000, respondent assessed petitioner’s share of the 1980 joint deficiency and sent petitioner a notice of balance due. On November 29, 2001, respondent issued a Final Notice–-Notice of Intent to Levy and Notice of Your Right to a Hearing. On December 14, 2001, petitioner timely submitted Form 12153, Request for a Collection Due Process Hearing, requesting a hearing under section 6330. At the section 6330 hearing, petitioner’s counsel argued that the limitations period had expired before respondent assessed petitioner’s 1980 income tax liability. Petitioner’s counsel raised no other issues, although counsel expressed interest in discussing an installment agreement if the Appeals Officer rejected his limitations argument. 2On Aug. 4, 1986, at petitioner’s request, Mr. Berg had filed a petition for redetermination of petitioner’s 1981 and 1982 income tax deficiencies.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011