- 2 - Greg A. Bell, pro se. Stephen J. Neubeck, for respondent. OPINION FOLEY, Judge: The issue for decision is whether respondent abused his discretion when he precluded petitioner, at the 2005 hearing, from challenging petitioner’s underlying tax liability and sustained the Notice of Federal Tax Lien relating to petitioner’s 1997 liability. Background Petitioner failed to file his 1997 Federal income tax return. By notice dated September 15, 2000, respondent determined a deficiency in, and additions to, petitioner’s 1997 Federal income tax. Respondent mailed such notice to petitioner, but petitioner did not receive it. On April 27, 2002, a Notice of Intent to Levy and Notice of Your Right to a Hearing relating to 1997 was mailed to petitioner. On May 22, 2002, petitioner timely filed a Form 12153, Request for a Collection Due Process Hearing (2002 request). In the 2002 request, petitioner contended that he “was never provided proof of the amount allegedly owed, neither in direct documentation, nor statements of how rules/laws and calculations were applied.” The Appeals officer scheduled a hearing for October 5, 2002 (2002 hearing). In a letter datedPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011