Garrett Lawrence Bailey - Page 9

                                        - 9 -                                         
          Notice of Determination and Tax Court Petition                              
               On March 10, 2004, respondent sent petitioner a Notice of              
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 (notice of determination) for tax years 1995, 1996,             
          and 1999.  In the notice of determination, respondent determined            
          the following:                                                              
               1.  All legal and procedural requirements for proceeding               
          with collection have been met;                                              
               2.  Petitioner was properly precluded from submitting an               
          offer-in-compromise because he did not submit Form 433-A and his            
          delinquent 2001 and 2002 tax returns as required and because                
          petitioner was not current with his filing obligations;                     
               3.  Petitioner was properly precluded from challenging his             
          1995 and 1996 income tax liabilities because respondent had                 
          issued a notice of deficiency for 1995 and 1996, and petitioner             
          had not provided any evidence to prove that petitioner did not              
          receive the notice of deficiency;                                           
               4.  Petitioner failed to submit any evidence to substantiate           
          that the income tax liability reported on his 1999 return was               
          incorrect; and                                                              
               5.  Petitioner failed to submit any evidence to establish              
          that the proposed levy does not balance the need for efficient              
          collection of taxes with the legitimate concern that any                    
          collection action be no more intrusive than necessary.                      






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