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Petitioner’s 1996-99 Tax Liabilities
Petitioner failed to file timely Federal income tax returns
for 1996, 1997, 1998, and 1999. These returns have since been
filed. On December 1, 2000, respondent made assessments against
petitioner for taxable years 1996, 1997, and 1999, apparently on
the basis of amounts shown as tax on petitioner’s late-filed
returns. On December 8, 2000, respondent sent petitioner a
Notice of Federal Tax Lien Filing and Your Right to a Hearing
Under I.R.C. � 6320, relating to petitioner’s 1996, 1997, and
1999 income tax liabilities. On December 12, 2000, respondent
sent petitioner a Final Notice, Notice of Intent to Levy, and
Notice of Your Right to a Hearing, relating to petitioner’s 1996,
1997, and 1999 income tax liabilities. On or about December 29,
2000, in response to these notices, petitioner filed a timely
Form 12153, Request for a Collection Due Process Hearing,
challenging the legality of the continuing wage levy and raising
issues relating to financial hardship.
Notice of Determination
On November 27, 2001, after a hearing, respondent’s Appeals
Office issued petitioner a notice of determination sustaining the
notice of Federal tax lien filing for petitioner’s 1996, 1997,
and 1999 income tax liabilities but determining that petitioner’s
4(...continued)
failed to establish that the levy had caused a hardship.
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Last modified: May 25, 2011