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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 a
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Last modified: May 25, 2011