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On July 3, 2001, respondent mailed a Final Notice-Notice of
Intent to Levy and Notice of Right to a Hearing (the notice of
levy) to petitioner. The notice of levy states that petitioner
owes $4452 of tax for 1982, $1,682 of tax and $4,495 in
“statutory additions” for 1987, and $3,548 of tax and $7,673 in
“statutory additions” for 1988. The notice of levy also states
that “the amount(s) shown does not include accured [sic]
penalties and/or interest.”
On or about July 10, 2001, petitioner submitted to the IRS
Appeals office an IRS Form 12153, Request for a Collection Due
Process Hearing. In his request, petitioner states his grounds
for requesting the hearing as follows:
I did not consent to extension of time to
collect the taxes. The Form was blank when I
signed it.
On December 21, 2001, Appeals Officer Dan Mazaroli sent a
letter to petitioner’s representative and, on January 8, 2002, he
sent a letter to petitioner, both letters requesting that he be
contacted in order to schedule the requested hearing. An
exchange of letters between Appeals Officer Mazaroli and
petitioner’s representative dated January 16, 2002, and
2 Both the certificate of assessments and payments and the
MFTRA-X transcript for 1982 show that, subsequent to the July 3,
2001, issuance of the notice of levy, a $500 “overpaid credit”
and an offsetting $55 interest assessment were applied to 1982,
which would account for the zero balance of tax owed for that
year, as of Dec. 31, 2001, that is reflected on both.
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Last modified: May 25, 2011