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Petitioner timely filed a Form 1040 for 2000 reflecting a
tax liability of $11,976, but he failed to pay the liability in
full. Respondent assessed the tax as well as an addition to tax
for failure to pay tax of $8.80 and credited his account for
Federal withholding taxes of $10,215. Respondent also credited
$500 to petitioner’s account for the Immediate Tax Relief Credit
on August 6, 2001. Including interest, petitioner’s outstanding
tax liability for 2000 was $1,635.36 as of the date of the Notice
of Intent to Levy. Petitioner has not made any other payments
toward his liability for 2000.
Respondent mailed to petitioner a Final Notice of Intent to
Levy and Notice of Your Right to a Hearing, that, among other
things, informed petitioner that respondent intended to levy to
collect the 1997 and 2000 liabilities and that petitioner could
request a hearing with respondent’s Appeals Office. Petitioner
submitted a timely Form 12153, Request for a Collection Due
Process Hearing (hearing).
1. Petitioner’s Hearing
Respondent’s Appeals Officer, Janet E. Spaulding (Ms.
Spaulding), held a hearing with petitioner via telephone. During
the hearing, petitioner requested that Ms. Spaulding consider the
1988, 1998, and 1999 tax years, in addition to 1997 and 2000.
Ms. Spaulding informed petitioner that she could not
consider the 1988 year because a lien for that year was filed in
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