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Upon receipt of the 1998 income tax return, respondent
assessed the tax due of $8,122, an addition to tax for failure to
timely file a return under section 6651(a)(1) of $1,827, an
addition to tax for failure to timely pay the tax under section
6651(a)(2) of $1,015, and an addition to tax for failure to pay
estimated tax under section 6654 of $257 against petitioner.
Respondent did not issue a notice of deficiency to petitioner.
On April 9, 2003, respondent sent petitioner a Notice of
Federal Tax Lien and Your Right to a Hearing Under IRC 6320 for
1998.
On May 5, 2003, respondent received petitioner’s request for
a section 6330 hearing. Theresa M. Amper (Ms. Amper), Appeals
Collection Specialist, sent confirmation of receipt on July 31,
2003, and requested that petitioner complete a Form 433-A,
Collection Information Statement for Individuals. Petitioner did
not respond.
Ms. Amper sent a second letter on August 25, 2003,
requesting petitioner complete a Form 433-A, and stating that if
she did not hear from petitioner by September 9, 2003, his
section 6330 hearing would consist of an administrative review of
his file. Petitioner did not respond.
On September 24, 2003, Appeals Officer Gerry Melick (Ms.
Melick) sent petitioner a letter requesting that petitioner
contact her by phone to discuss petitioner’s section 6330 hearing
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Last modified: May 25, 2011