- 5 -
We summarize the foregoing chronology with the following
table:
Tax
Year Date Return Filed Liability Credits
1994 5/14/1997 $32,490.86 $43,677.64
1995 8/14/2001 29,065.18 41,814.78
1996 8/2001 or 3/26/2002 33,210.00 37,632.00
1997 10/3/2001 34,456.00 28,743.00
Respondent seeks to collect the balance of the unpaid tax
liability, plus any accrued interest and additions to tax, for
1997. Respondent issued petitioner a notice of intent to levy on
or about April 20, 2002.
At a hearing before respondent’s Appeals officer,5
petitioner was presented with literal transcripts of his tax
accounts for the years 1994 through 1998. On August 28, 2002,
the Appeals Office issued the Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330, notifying
petitioner of the determination to proceed with collection of the
1997 income tax liability.
In his petition to this Court, filed September 20, 2002,
petitioner alleged in part:
I sent a check in the amount of $5,000. 4/4/86 to
the Internal Revenue Service which was never
acknowledged. I have sent letters to the Internal
Revenue Service for years asking about this money.
5 The parties did not provide us with a copy of the Form
12153, Request for a Collection Due Process Hearing, submitted by
petitioner.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011