- 2 -
(IRS) in determining that collection of petitioner’s unpaid
income tax liabilities for 2001 should proceed.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
Petitioner resided at the Federal Correction Institution in
Ashland, Kentucky, at the time that he filed his petition.
Petitioner did not file a Form 1040, U.S. Individual Income
Tax Return, for 2001. A notice of deficiency was sent to
petitioner on January 21, 2004. Petitioner never disputed the
determinations in the notice. Instead, he repeatedly sent
letters to the IRS asserting that he wished to cooperate with the
IRS, but only upon receipt of written confirmation that the
information that he provided to the IRS would, at no time or in
any way, be used in a criminal investigation or criminal
prosecution against him. After the time for filing a petition in
response to the statutory notice had passed, unpaid taxes,
penalties, and interest were assessed.
On June 27, 2005, the IRS sent to petitioner a Final Notice
of Intent to Levy and Notice of Your Right to a Hearing (final
notice). In response to the final notice, petitioner sent to the
IRS a Form 12153, Request for a Collection Due Process Hearing
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011