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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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Last modified: May 25, 2011