Harold E. Call - Page 3

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               Respondent issued to petitioner by certified mail a                    
          statutory notice of deficiency for 1998 on February 11, 2000, and           
          for 1999 on March 30, 2001.  Petitioner did not file a petition             
          with this Court in response to either notice of deficiency, and             
          respondent assessed the taxes, additions to tax, penalty, and/or            
          interest for 1998 on August 14, 2000, and for 1999 on September             
          24, 2001.  A notice of balance due was promptly sent to                     
          petitioner with respect to each year.                                       
               Thereafter, respondent issued to petitioner a Notice of                
          Federal Tax Lien Filing and Your Right to a Hearing Under IRC               
          6320 regarding his unpaid liabilities for 1998 and 1999.  On or             
          about April 16, 2003, petitioner submitted to respondent a Form             
          12153, Request for a Collection Due Process Hearing, setting                
          forth his disagreement with the lien.  He challenged, among other           
          things, the validity of the assessments, the issuance of a                  
          statutory notice of deficiency or notice and demand for payment,            
          and the authority of Internal Revenue Service personnel.  A cover           
          letter with the Form 12153 indicated that petitioner had                    
          initially attempted to respond to respondent’s proposed                     
          collection activities by a letter dated March 26, 2003, and also            
          stated petitioner’s intention to record the requested hearing.              
               The Appeals officer to whom petitioner’s case had been                 
          assigned subsequently scheduled a hearing for July 2, 2003, in              
          Las Vegas, Nevada.  Petitioner appeared for the scheduled hearing           






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