- 4 -
Petitioner4 did not file a petition in the Court with re-
spect to the notice relating to taxable years 1997 and 1998.
On February 5, 2001, respondent assessed petitioner’s tax,
as well as an accuracy-related penalty under section 6662(a) and
interest as provided by law, for each of the taxable years 1997
and 1998 (respondent’s assessment for each of the taxable years
1997 and 1998). (We shall refer to any such unpaid assessed
amounts, as well as interest as provided by law accrued after
February 5, 2001, as petitioner’s respective unpaid liabilities
for 1997 and 1998.)
On a date not disclosed by the record that was within 60
days after the date on which respondent made respondent’s assess-
ment for each of the taxable years 1997 and 1998, respondent
issued to petitioner a notice of balance due with respect to
petitioner’s respective unpaid liabilities for 1997 and 1998, as
required by section 6303(a).
On May 11, 2001, respondent issued to petitioner a final
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to taxable years 1997 and
1998.
On May 24, 2001, respondent issued to petitioner a notice of
Federal tax lien filing and your right to a hearing (notice of
4This case involves only petitioner, and not Mr. Dues. For
convenience, we shall hereinafter refer only to petitioner, and
not to petitioner and Mr. Dues.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011