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Appeals Office issued petitioner a decision letter upholding the
proposed levy.
In a letter dated October 22, 1999, Revenue Officer Mele
informed petitioner that respondent would begin levying on his
income sources and assets on November 5, 1999.
On or about November 8, 1999, petitioner submitted a Form
9423, Collection Appeal Request, in which he attributed the
delays in filing his returns to respondent’s failure to follow
through on petitioner’s request for capital loss carryover
information from 1987 that he needed to file his returns for the
tax years at issue. Petitioner’s Form 9423 states that Revenue
Officer Mele was unable to obtain petitioner’s 1987 return.
On or about December 7, 1999, petitioner submitted to
Revenue Officer Mele a request to enter into an installment
agreement to pay his tax liabilities for 1992 through 1994. On
January 11, 2000, Revenue Officer Mele sent a letter to
petitioner’s post office box address denying petitioner’s request
for an installment agreement because petitioner had not filed
income tax returns for 1992 through 1999. The January 11, 2000,
letter specifically instructed petitioner to send an appeal
request to Revenue Officer Mele at his office address on or
before February 11, 2000, if petitioner wished to appeal the
denial of his installment agreement request. Petitioner did not
appeal the denial of his installment agreement request.
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Last modified: May 25, 2011