- 2 - Background At the time of the filing of the petition, petitioner resided in Levittown, Pennsylvania. Petitioner failed to file Federal income tax returns for the 1998, 1999, and 2000 tax years. Consequently, respondent sent petitioner a notice of deficiency for those 3 years, dated January 31, 2003. Petitioner received the notice but did not petition this Court for a redetermination with respect to the notice. Petitioner filed an untimely Federal income tax return for the 2001 tax year but failed to pay the taxes due. Respondent sent petitioner two Letters 1058, Final Notice-- Notice of Intent to Levy and Notice of Your Right to a Hearing, both dated June 9, 2004. On June 29, 2004, respondent received a timely Form 12153, Request for a Collection Due Process Hearing, which petitioner submitted for the 1998, 1999, 2000, and 2001 tax years. Respondent’s Appeals officer and petitioner held a telephone hearing on November 10, 2004. During the hearing, petitioner stated that he “already paid more taxes than he should have” and “had no federal taxes withheld during the years at issue because no one told him otherwise”. Respondent’s Appeals officer discussed collection alternatives with petitioner. However, petitioner stated that he did not want to pay the outstanding liabilities and wanted to proceed to court. On November 17, 2004, respondent issued to petitioner aPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011