John A. Seavey - Page 6

                                        - 5 -                                         
          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           






Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011