- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011