Robert E. Crandall - Page 3

                                        - 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                 
               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