Ferrel Benjamin Gibbs - Page 2

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          (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              






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