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For its taxable year ending June 30, 1998, 100 Oak Street
did not file a timely section 6033(a)(1) return. On November 1,
1999, respondent assessed a section 6652(c)(1) penalty of $2,460
against 100 Oak Street for failure to timely file a section
6033(a)(1) return. A notice of deficiency was not issued.
Pursuant to section 6330(a), respondent issued 100 Oak
Street a Final Notice of Intent to Levy and Notice of Your Right
to a Hearing (notice of intent to levy) on December 18, 2002. A
section 6330 hearing requested by 100 Oak Street was held on
December 10, 2003.
For its taxable year ending June 30, 1999, Service Employees
did not timely file a section 6033(a)(1) return. On April 8,
2002, respondent assessed a section 6652(c)(1) penalty of $50,000
against Service Employees for failure to timely file a section
6033(a)(1) return. A notice of deficiency was not issued.
Pursuant to section 6330(a), respondent issued Service
Employees a notice of intent to levy on August 13, 2002. Service
Employees requested a section 6330 hearing, which was held on
September 10, 2003.
On April 23, 2004, respondent sent each petitioner a Notice
of Determination Concerning Collection Actions Under Section
6330, upholding the respective levies. On May 21, 2004,
petitioners filed petitions with this Court seeking review of
respondent’s determinations.
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Last modified: May 25, 2011