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primarily of the assessed interest and addition to tax resulting
from the late filing of petitioner’s 1999 return.5
On December 12, 2002, respondent issued petitioner a Final
Notice of Intent to Levy with respect to petitioner’s 1995, 1996,
and 1999 tax liabilities.
Petitioner’s Health Problems During 1998-2000
In late 1998 and throughout 1999, petitioner suffered from a
liver ailment. In June 1999, petitioner’s doctor recommended
that petitioner obtain a liver transplant consultation. In
December 1999, petitioner was placed on the UCLA liver transplant
list. During 2000, petitioner underwent several surgeries,
including a liver transplant.
Although petitioner experienced pain and some loss of
function from his liver condition during the period of his
illness, he continued to work at the law firm and to make court
appearances, except for a 6-month period in connection with his
surgeries.
Section 6330 Hearing
On January 9, 2003, petitioner timely filed a Request for a
Collection Due Process Hearing (section 6330 hearing) for 1995,
5Form 4340 for 1999 reveals that respondent assessed an
income tax liability of $9,627 in connection with the filing of
petitioner’s 1999 return. The record does not explain why the
assessed income tax liability of $9,627 is higher than
petitioner’s reported income tax liability of $9,417. However,
petitioner offered no evidence at trial that the assessment was
incorrect.
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