Fred Deutsch - Page 5

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         overpayment of $248,093.  At that time, petitioner also filed                
         returns for 1998 through 2002 that reflected tax liabilities of              
         $11,484 for 1998 and $22,099 for 1999 and overpayments of tax of             
         $132,870 for 2000, $131,289 for 2001, and $242,448 for 2002 (a               
         net overpayment of $473,024).                                                
              Mr. Stechel sent copies of the 1995 and 1996 returns and the            
         amended return for 1997 to Appeals Officer Azim.  In the cover               
         letter, Mr. Stechel stated:  “As we previously discussed, I am               
         enclosing a set of the returns being filed contemporaneously on              
         behalf of the taxpayer.  I believe that these filings will render            
         moot the necessity for a Collection Due Process hearing.  Please             
         call me if you have had the opportunity to review these                      
         enclosures.”                                                                 
              Respondent did not accept the returns for 1995 and 1996 or              
         the amended return for 1997.  Respondent accepted the returns for            
         1998 through 2004.  Respondent did not credit the overpayment                
         petitioner claimed for 2000 because credit or refund of the                  
         overpayment was barred by section 6511(b)(1).                                
              On January 21, 2005, respondent’s Appeals Office mailed to              
         petitioner a Notice Of Determination Concerning Collection                   
         Action(s) Under Section 6320 and/or 6330, sustaining the filing              
         of the levy notice against petitioner.  On February 24, 2005,                
         petitioner timely filed with the Court a petition challenging                
         respondent’s notice of determination.                                        






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