Jonathan Kaplowitz - Page 2

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          Background2                                                                 
               Petitioner failed to file Federal income tax returns for the           
          taxable years 1996 through 2000.  A notice of deficiency was                
          issued on June 19, 2002, determining deficiencies and additions             
          to tax for the taxable years 1996 through 2000.  Petitioner                 
          received the notice of deficiency and acknowledged receipt to               
          representatives of respondent.  A timely petition was not filed             
          with this Court in response to the June 19, 2002, notice of                 
          deficiency.  The deficiencies, additions to tax, and interest               
          were assessed on November 11, 2002.                                         
               On August 21, 2003, respondent mailed a Final Notice-–Notice           
          of Intent to Levy and Notice of Your Right to a Hearing with                
          regard to petitioner’s tax liabilities for 1996 through 2000.               
          Petitioner submitted a timely request for hearing.  Petitioner              
          was advised by the Appeals officer that the issue of the                    
          underlying tax liability would not be the subject matter of the             
          hearing.  See sec. 6330(c)(2)(B).  Petitioner was also advised              
          that respondent could consider collection alternatives and that             


               1(...continued)                                                        
          Revenue Code, as amended, and Rule references are to the Tax                
          Court Rules of Practice and Procedure.                                      
               2  The background factual information is derived from                  
          respondent’s determination letter dated Dec. 16, 2003.                      
          Petitioner does not appear to dispute the factual narrative                 
          provided by the IRS Appeals officer with respect to the failure             
          to file returns, the issuance of a notice of deficiency and a               
          final notice of intent to levy, and the subsequent hearing held             
          with the Appeals officer.                                                   




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