- 3 - Taxable Year Liability 1990 $14,276.52 1991 5,185.82 1994 7,125.11 1995 21,075.43 1996 6,448.00 1997 13,362.68 1998 21,936.82 2002 2,969.31 $92,379.69 On June 2, 2004, respondent mailed to petitioner a Final Notice - Notice of Intent to Levy and Notice of Your Right to a Hearing, for petitioner’s 1990, 1991, 1994, 1995, 1996, 1997, 1998, and 2002 taxable years. In response, petitioner timely filed a Form 12153, Request for a Collection Due Process Hearing. With the Form 12153, petitioner submitted a statement contending, inter alia, that petitioner was incapable of paying the accrued interest and penalties, that the IRS misplaced three separate offers-in-compromise previously submitted by petitioner, that moving to a less expensive home was not financially feasible, and that petitioner supports a child. Respondent’s Appeals Office assigned the case to Settlement Appeals Officer Frank Kowalkowski (Appeals Officer Kowalkowski), who had no prior experience with petitioner’s tax years in issue. On December 16, 2004, Appeals Officer Kowalkowski conducted a section 6330 hearing with petitioner by telephone. On January 26, 2005, respondent’s Appeals Office issued petitioner a Notice of Determination Concerning Collection Action(s) Under SectionPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011