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items constituting the record. There appears to be no
disagreement as to the following facts.
Petitioner filed his 1994 Federal income tax return (the
1994 return) on April 16, 1997, reporting tax of $2,084, no
withholding or estimated tax payments, and an estimated tax
penalty of $107. Petitioner did not remit any amount with the
1994 return. On May 19, 1997, respondent assessed the tax
liability shown on the 1994 return and issued to petitioner a
notice and demand for payment with respect thereto.
Petitioner filed his 1996 Federal income tax return (the
1996 return) on April 15, 1997, reporting tax of $66,874, no
withholding or estimated tax payments, and an estimated tax
penalty of $270. Petitioner did not remit any amount with the
1996 return. On June 2, 1997, respondent assessed the tax
liability shown on the 1996 return and issued to petitioner a
notice and demand for payment with respect thereto.
Petitioner did not make the payments demanded, and, on
January 23, 2001, respondent notified petitioner of his intent to
levy with respect to petitioner’s unpaid tax liabilities for 1994
and 1996. In response, petitioner timely submitted to respondent
Form 12153, Request for a Collection Due Process Hearing. In the
request, petitioner, a songwriter, stated his belief that the
taxes shown on the 1994 and 1996 returns (together, the returns)
are incorrect. He explained that he was in a dispute with
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