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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 Section
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Last modified: May 25, 2011