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alleging that additional information for the year could alter the
decision to be entered. On February 27, 2002, this Court ordered
petitioner to file an alternative computation by March 25, 2002.
Petitioner failed to file an alternative computation, and on
April 26, 2002, a decision was entered determining deficiencies
in income tax for the taxable years 1993 and 1994 of $9,228 and
$17,369, respectively.
On January 4, 2003, respondent sent petitioner a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing
(levy notice) for petitioner’s 1993 and 1994 taxable years. The
levy notice reflected an unpaid tax liability (including
interest) of $10,109 for the 1993 taxable year and $33,195 for
the 1994 taxable year.
On February 2, 2003, respondent received petitioner’s timely
Form 12153, Request for a Collection Due Process Hearing
(request), for taxable years 1992, 1993, and 1994. As a basis
for his request, petitioner attached documents showing that he
had objected to respondent’s original decision. Petitioner’s
original section 6330 hearing was scheduled for November 19,
2003, but it was rescheduled for a later date because of
conflicts. Petitioner failed to appear for the rescheduled
meeting. On February 4, 2004, respondent mailed petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (final notice) determining that the
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Last modified: May 25, 2011