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On November 1, 2001, petitioner submitted a Form 12153,
Request for a Collection Due Process Hearing, requesting a
hearing under section 6330 with respect to the 1997 taxable year.
On the form, petitioner stated, in part, that the Form 1099-C
income should be charged to the corporation and any tax liability
resulting from that income should be treated as the corporation’s
liability.
Following his request for an administrative hearing, in a
February 22, 2002, telephone conversation petitioner informed
respondent’s Appeals officer that he would provide additional
information with respect to the discharged debt.
On March 15, 2002, petitioner was contacted by an Appeals
officer. Petitioner informed the Appeals officer that he was
trying to obtain the supporting documentation with respect to the
discharged debt. On April 18, 2002, the Appeals officer again
spoke with petitioner and was told that petitioner had not been
able to obtain the necessary information from First Madisonville.
After receiving no information from petitioner, the Appeals
officer informed petitioner by letter that a hearing was
scheduled for May 27, 2002. Petitioner canceled the meeting and
rescheduled it for June 11, 2002. On June 10, 2002, petitioner
canceled the second scheduled hearing.
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Last modified: May 25, 2011