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1994, and 1995. On April 27, 1999, the bankruptcy court
dismissed petitioner's case.
Assessments/Collection Actions for 1983 and 1993 to 1995
On May 10, 1990, respondent entered assessments against
petitioner for the income tax and additions to tax for the
taxable year 1983 as set forth in the Court's decision at docket
No. 27411-88, as well as statutory interest. On May 10, 1990,
and June 11, 1990, respondent issued to petitioner notices of
balance due for the year 1983.5 Petitioner failed to remit to
respondent the amount due.
On April 30, 2001, respondent entered assessments against
petitioner for the income taxes and additions to tax for the
years 1993, 1994, and 1995 as set forth in the Court's decision
at docket No. 18627-97, as well as statutory interest. On April
30, 2001, respondent issued to petitioner notices of balance due
for the years 1993, 1994, and 1995. Petitioner failed to remit
to respondent the amounts due.
On December 17, 2001, respondent issued to petitioner a
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing requesting that petitioner pay his outstanding income
taxes for the years 1983 and 1993 to 1995. On January 9, 2002,
5 The record reflects that respondent subsequently abated
all of the originally assessed additions to tax for 1983. The
record also shows that in 1991 respondent collected a small
portion of the amount due from petitioner for 1983 by levy.
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Last modified: May 25, 2011