Ronald Lee Snyder - Page 7

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               On January 16, 2003, a settlement officer with respondent's            
          Appeals Office (settlement officer) held one hearing with peti-             
          tioner that the settlement officer considered to be both an                 
          Appeals Office hearing with respect to the notice of tax lien and           
          an equivalent hearing with respect to the notice of intent to               
          levy.  During that hearing, the settlement officer relied on a              
          transcript of petitioner’s account with respect to each of his              
          taxable years 1991, 1994, 1996, 1998, and 1999.                             
               On March 25, 2003, the Appeals Office issued to petitioner a           
          notice of determination concerning collection action(s) under               
          section 6320 (notice of determination) in which that office                 
          sustained the notice of tax lien.  An attachment to the notice of           
          determination stated in pertinent part:                                     
                                  BRIEF BACKGROUND                                    
               The taxpayer filed voluntary income tax returns for                    
               1991, 1994, 1996.  The Collection Statute has since                    
               expired on the 1991 tax liability.  The taxpayer filed                 
               frivolous returns for 1997, 1998 and 1999.  Frivolous                  
               return penalties were assessed for each of these three                 
               years.  The taxpayer has filed no income tax returns                   
               since 1999 even though income information reported to                  
               the Internal Revenue Service indicates that he would                   
               have a filing requirement.                                             
                  *       *       *       *       *       *       *                   





               6(...continued)                                                        
          tioner’s Form 12153 was timely filed with respect to the notice             
          of intent to levy.                                                          




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