Harvey L. Hoover - Page 19

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          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.             






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