- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011