- 3 - Revenue Service (IRS) notified petitioner of disallowance of the refund claim and of his right to contest the denial by filing a lawsuit in the U.S. District Court or U.S. Court of Federal Claims. With respect to 1999, the IRS examined petitioner’s filed return and issued a statutory notice of deficiency. Petitioner did not file a petition with this Court in response to the notice of deficiency, and respondent assessed the tax, an addition to tax, and interest for 1999 on November 19, 2001. Notices of balance due were promptly sent to petitioner with respect 1999. Thereafter, on August 5, 2002, respondent issued to petitioner a Final Notice of Intent To Levy and Notice of Your Right To a Hearing regarding his unpaid liabilities for 1998 and 1999. Petitioner timely submitted to respondent a Form 12153, Request for a Collection Due Process Hearing, setting forth his disagreement with the levy, as follows: “NOT LIABLE, MORE DETAILS TO FOLLOW”. By a letter dated February 20, 2003, Julieanne M. Petersen, the Appeals officer to whom petitioner’s case had been assigned, scheduled a hearing for March 20, 2003, in Las Vegas, Nevada.2 The letter briefly outlined the hearing process, advised that audio or stenographic recording of hearings was not allowed, and 2 The explanation attached to the Apr. 23, 2003, notice of determination apparently refers in error to Mar. 28, 2003, as the date initially scheduled for the requested hearing.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011