-4- C. The Section 6330 Hearing Respondent issued a Final Notice, Notice of Intent to Levy and Notice of Your Right to a Hearing, on November 8, 2000. In the Final Notice, respondent stated that petitioner owed $270,087.60 for 1989, $108,044.26 for 1990, and $5,507.84 for 1999. On December 1, 2000, petitioner sent to respondent a Form 12153, Request for a Collection Due Process Hearing. Petitioner was incarcerated at the Wyoming Correctional Facility at that time. He attached an explanation in which he said he had not received the notice of deficiency and that he was not liable for tax in the amounts stated in the notice. One of respondent’s Appeals officers was assigned to petitioner’s case on February 12, 2002. The Appeals officer kept an activity log for the case in which he said: (1) The case is very complex; (2) petitioner claims that he had no prior opportunity to contest the underlying liability and he did not receive the notice of deficiency; and (3) the “administrative file indicates that a defaulted * * * [notice of deficiency] is in [the administrative] file”. On May 1, 2002, the Appeals officer sent a letter to petitioner at the Wyoming Correctional Facility stating in part: We scheduled the conference you requested on this case for * * * [9:30 a.m., May 21, 2002, at room 1137, 290 Broadway, New York, New York]. Please let me know within 10 days from the date of this letter whetherPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011