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petitioner transcripts of his tax accounts. These transcripts
reflected the tax liabilities petitioner reported on his returns,
plus additions to tax, interest, and collection costs. The
parties were unable to resolve the matter, and Ms. Frazier issued
a notice of determination sustaining respondent's Notice of
Federal Tax Lien as the appropriate means of collecting
petitioner's unpaid liabilities for 1992, 1998, and 2000.
2. The Petition
The petition petitioner filed with this Court covered tax
years 1990, 1992, 1998, 2000, 2001, and 2002. Because the notice
of determination addressed only 1992, 1998, and 2000,
respondent's motion to dismiss for lack of jurisdiction and to
strike as to the remaining years was granted.
In his petition, petitioner states:
I dispute the amounts I am being billed for. Some
years are correct, others the IRS claim [sic] to be
self-reported income taxes but which start out with a
balance due of $7,159.21. This has yet to be verified
but accrues interest and penalties.
During certain years I was financially eligible for an
offer in compromise but could not get my case reviewed.
I disagree with the determination.
Discussion
Section 6320 entitles a taxpayer to notice of the taxpayer's
right to request a hearing after a notice of lien is filed by the
Commissioner in furtherance of the collection from the taxpayer
of unpaid Federal taxes. The taxpayer requesting the hearing may
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Last modified: May 25, 2011