Julian Quinton Johnson - Page 4

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             to that record, “the Settlement Appeals Officer fully                    
             responded to petitioner’s challenge to the proposed                      
             collection action” and “fully complied with the                          
             requirements of Code section 6330(c)” and “there was no                  
             abuse of discretion”.                                                    
                                      Background                                      
                  The tax for each of the years in issue was assessed by              
             respondent before the notice of determination was issued.                
             For 1991, respondent assessed the tax after petitioner did               
             not respond to a notice of deficiency that respondent had                
             issued to petitioner.  Petitioner had filed no return for                
             the year.  With respect to the other taxable years involved              
             in this case, 1996, 1998, and 1999, petitioner did not pay               
             all of the tax reported on the return filed for each of                  
             those years.  Accordingly, respondent assessed the unpaid                
             amounts.                                                                 
                  The record suggests that a notice of each of the                    
             above assessments and a demand for payment were issued to                
             petitioner in accordance with section 6303(a).  In due                   
             course thereafter, respondent issued to petitioner a                     
             final notice of intent to levy and notice of the right to                
             a hearing, pursuant to section 6330(a).  A copy of that                  
             notice is not included in the record.                                    






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