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failed to report $9,587 of wages received from American
Protective, $4,523 of wages received from Smith Security Corp.,
$6,191 of a taxable distribution from John Hancock, $925 of a
taxable distribution received from BT Svcs. Tenn., $18 of
interest received from NBD Bank, and $843 of Social Security
payments.
By separate letters to respondent dated February 20, 2001,
petitioner acknowledged receiving the deficiency notices and
questioned respondent’s authority to issue these notices.
Petitioner did not file a petition for redetermination with the
Court contesting the deficiency notices, however.
Respondent mailed to petitioner a Final Notice - Notice of
Intent to Levy and Notice of Your Right to a Hearing Under
Section 6330 (final notice) on July 12, 2002, with regard to
petitioner’s unpaid Federal income taxes for 1998 and 1999. A
schedule attached to the final notice stated that petitioner owed
an assessed balance of $717.45 plus statutory additions of $69.95
for 1998 and an assessed balance of $3,402.77 for 1999.
Petitioner timely filed with respondent a Request for a
Collection Due Process Hearing, which included frivolous
allegations that the proposed levy should be barred for several
reasons. First, petitioner alleged that respondent purportedly
failed to issue to petitioner “valid” notices of deficiency
because the Internal Revenue Service (IRS) does not have the
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