- 19 - collection of income tax for the periods of 1989 through 1992.” The letter also advised petitioner of his appeal rights pursuant to section 7429. On June 30, 1999, respondent filed a notice of Federal tax lien in the Wabash, Indiana County Recorder’s Office regarding jeopardy assessments of income taxes, interest, and penalties for 1989, 1990, 1991, and 1992. On July 5, 1999, respondent sent to petitioner a Letter 3172, Notice of Federal Tax Lien Filing and Right to a Hearing Under IRC Section 6320, regarding petitioner’s 1989, 1990, 1991, and 1992 tax years. Petitioner executed and mailed to respondent a Form 12153, Request for a Collection Due Process Hearing, dated July 23, 1999. In that Request for a Collection Due Process Hearing, petitioner appealed both the notice of Federal tax lien and the notice of levy. On September 13, 1999, the Appeals officer sent a letter to petitioner establishing a conference date of October 20, 1999. By letter dated September 22, 1999, petitioner requested that the conference be moved to Cleveland, Ohio, where he was incarcerated. Sometime between December 8, 1999, and January 11, 2000, respondent’s Appeals officer and petitioner conducted a telephone conference regarding petitioner’s request for a hearing. During the telephone conference, petitioner did not question the amounts of gross income respondent determined for 1990, 1991, and 1992.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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