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economic hardship, the taxpayer must submit complete financial
data.
Petitioner, however, has never supplied a completed Form
433-A or other financial information to respondent, despite
requests from respondent and the efforts and warnings of his own
representative. Mr. Lynch’s June 13, 2002, letter, of which a
copy was sent to petitioner, expresses clearly that petitioner
would be expected to provide relevant financial disclosure forms
at the June 26, 2002, meeting in order to prevent closure of his
case and resumption of collection activity. In light of this
admonition, petitioner’s continued recalcitrance after the
conference with regard to supplying the necessary data is not
well taken.
Consequently, although the Court is sympathetic to
difficulties petitioner may have encountered in connection with
his health and economic situation, it cannot be said that
respondent acted arbitrarily or capriciously in determining to
proceed with levy for 1985 when petitioner submitted no
documentation, during or after a proper hearing, of his financial
circumstances. The Court shall sustain respondent’s collection
action with respect to 1985.
B. 1999
With respect to 1999, petitioner’s submissions to this Court
focus solely on his contention that he did not receive a “due
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