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Background
On February 5, 2004, respondent sent petitioner a notice of
intent to levy and right to a hearing regarding income taxes owed
for 2001.
On June 3, 2004, respondent sent petitioner a notice of
intent to levy and right to a hearing regarding income taxes owed
for 1999 and 2000.
On June 8, 2004, respondent sent petitioner a notice of
deficiency listing a deficiency of $21,518, an addition to tax
pursuant to section 6651(a)(1)1 of $6,240.22, and an addition to
tax pursuant to section 6654(a) of $719.07 for 2002.
On or about June 11, 2004, respondent sent petitioner a
notice of Federal tax lien filing and right to a hearing
regarding income taxes for 1999, 2000, and 2001 and penalty
pursuant to section 6702 for 1999 and 2000.
On June 16, 2004, petitioner requested a section 6330
hearing regarding the notice of Federal tax lien filing and the
notices of intent to levy for 1999, 2000, and 2001.
During August 2004, petitioner and respondent conducted by
correspondence a section 6330 hearing regarding (1) the notice of
lien regarding income taxes for 1999, 2000, and 2001 and penalty
pursuant to section 6702 for 1999 and 2000, and (2)
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: May 25, 2011