Christopher Michael Frazier - Page 2

                                        - 2 -                                         
          discretion in proceeding with a proposed levy on petitioner’s               
          assets.                                                                     
                                     Background                                       
               At the time of the filing of the petition in this case,                
          petitioner resided in Washington, D.C.  At all relevant times,              
          petitioner had outstanding income tax liabilities for taxable               
          years 1990, 1991, 1992, 1993, 1995, 1999, and 2000 (collectively,           
          petitioner’s unpaid tax liability).  On July 20, 2002, respondent           
          sent petitioner a Final Notice - Notice of Intent to Levy and               
          Notice of your Right to a Hearing (levy notice) with respect to             
          petitioner’s unpaid tax liability.  In response, on August 15,              
          2002, petitioner timely filed a Request for a Collection Due                
          Process Hearing (request) for taxable years 1990, 1991, 1992,               
          1993, 1995, 1999, and 2000.                                                 
               The request consisted, in its entirety, of the following:              
               I do not understand the Account Summary page total                     
               please explain to me what is going on [sic]                            
               Assessed Balance, Statutory Additions, Total, how did                  
               you come up with that balance. [sic] I would like to                   
               make monthly payment that I can aford. [sic] I do                      
               realize that it may take me the rest of my life to pay.                
               How do I start paying and were. [sic] Please contact me                
               by mail or phone * * * HELP                                            
               Between September 18, 2003, and July 13, 2004, petitioner              
          and respondent’s Appeals officer engaged in telephonic                      
          conversations and exchanged correspondence.  Petitioner and the             
          Appeals officer discussed collection alternatives, including an             






Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011