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addition to tax for 1994. Additionally, respondent assessed the
deficiency, penalty, and interest for tax year 1996.
Respondent filed a Notice of Federal Tax Lien with respect
to petitioner's tax liabilities. The unpaid balance was shown as
$35,991. Thereafter, respondent sent to petitioner, a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320, regarding the lien. Petitioner returned to respondent a
Form 12153, Request for a Collection Due Process Hearing. It was
signed only by petitioner, not by his wife.
On the Form 12153, petitioner supplied the following
explanation of his disagreement with the lien: "I was on
business and was filling [sic] income every year I was loss [sic]
large money on this business and the end of it I wass [sic]
closed this business The (illegible) I was loss [sic] large
money."
After an in-person hearing with petitioner, respondent
issued a Notice of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330 (collection notice) for tax years
1994, 1995, and 1996.
Petitioner's petition challenging the collection notice was
filed with the Tax Court and reflected an address for petitioner
at 316 Pennsylvania Avenue, Downingtown, Pennsylvania 19335. The
petition states:
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