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Background
Petitioners resided in Metuchen, New Jersey, when the
petition in this case was filed.
Petitioners filed late Federal income tax returns for the
taxable years 1989, 1990, 1992, and 1993. After examining
petitioners’ 1989 and 1990 returns, respondent determined
deficiencies for those years. When petitioners failed to
petition this Court within 90 days of the notices of deficiency
issued for 1989 and 1990, respondent assessed the unpaid taxes,
including penalties and interest. Respondent also assessed
unpaid income tax liabilities shown on petitioners’ 1992 and 1993
returns.
On July 30, 2002, respondent issued a notice pursuant to
section 6330(a) with respect to petitioners’ 1989, 1990, 1992,
and 1993 taxable years that informed petitioners of respondent’s
intent to levy and their right to a hearing. In response,
petitioners submitted Form 12153, Request for a Collection Due
Process Hearing (hereinafter section 6330 hearing), dated August
23, 2002. On January 29, 2004, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 sustaining the proposed levy action. The notice of
determination stated, in relevant part, the following: “If you
want to dispute this determination in court, you must file a
petition with the United States Tax Court for a redetermination
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