Randy R. Romano - Page 2

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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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