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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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Last modified: May 25, 2011