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Background
By notice of determination dated March 4, 2004, respondent
determined that, pursuant to section 6330,1 he could proceed to
collect by levy the following income tax liabilities:
Tax year Unpaid income tax liability
1992 $24,288.47
1993 11,297.73
1994 12,000.59
1995 3,530.29
1996 8,788.57
1997 4,199.26
1998 2,055.46
1999 814.34
Total 66,974.71
On March 12, 2004, petitioner mailed a letter to the Court,
which we filed on March 16, 2004, as petitioner’s imperfect
petition. Because the imperfect petition did not meet the
requirements of Rule 331(b), the Court ordered petitioner to file
a proper amended petition by May 3, 2004. On April 26, 2004, the
Court filed petitioner’s amended petition seeking review of
respondent’s determination to proceed by levy with collection of
petitioner’s Federal income tax liabilities and seeking a
redetermination of petitioner’s employment status2 with respect
1All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code in effect at all relevant times.
2Although petitioner checked the box on the petition form
indicating that his petition was for a redetermination of
employment status, petitioner appears to have done so as a result
of a misunderstanding. Petitioner is appealing respondent’s
(continued...)
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Last modified: May 25, 2011